SolvedCH225595 | How to do a compliance check: information powers: third party notice: groups: summary table
From HM Revenue & Customs · Compliance Handbook
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
| CH225520 | CH225530 | CH225540 | CH225550 | CH225560 | CH225570 | CH225580 | CH225590 | |
|---|---|---|---|---|---|---|---|---|
| Notice to | External third party | External third party | Parent | Parent | Parent | Parent | Subsidiary | Subsidiary |
| To check tax postion of | Parent and one or more known subsidiaries | One or more known subsidiaries only | Parent and one known subsidiary | Parent and more than one known subsidiary | One known subsidiary | More than one known subsidiary | Parent or one or more known subsidiaries | Parent and one or more known subsidiaries |
| Type of notice | 3 party | 3 party | Combined taxpayer and 3 party | Combined taxpayer and 3 party | 3 party | 3 party | 3 party | 3 party |
| Para 21/21A conditions, see CH23520 | No effect | No effect | Apply to parent but not subsidiary | Applies to parent and all subsidiaries unless each subsidiary is named. In which case it only applies to parent and the named subsidiaries | No effect | Applies to all subsidiaries unless each subsidiary is named. In which case it only applies to the named subsidiaries | No effect | No effect |
| Taxpayer approval required | Parent only | Each subsidiary | Subsidiary | None | Subsidiary | None | Parent or each subsidiary | Parent |
| Appeal grounds, if not tribunal approved | Too onerous only | Too onerous only | Any | Any | Too onerous only | Any | Too onerous only | Too onerous only |
| No appeal against | Statutory records of parent and each of its subsidiaries | Statutory records of each subsidiary | Statutory records of parent or the subsidiary | Statutory records of parent or any of its subsidiaries | Statutory records of subsidiary | Statutory records of parent or any of its subsidiaries | Statutory records of parent or each subsidiary | Statutory records of parent and each of its subsidiaries |
| Tribunal approval required | If no taxpayer approval | If no taxpayer approval | If no taxpayer approval | Optional | If no taxpayer approval | Optional | If no taxpayer approval | If no taxpayer approval |
| Opportunity to make representations | Recipient | Recipient | Recipient | Recipient | Recipient | Recipient | Recipient | Recipient |
| Summary of reasons | Parent only | Each subsidiary | Subsidiary | None | Subsidiary | None | Parent or each subsidiary | Parent |
| If tribunal, no appeal against | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice | Notice or any requirement in notice |
| Name in notice | [Parent name] and any of its subsidiaries | Each subsidiary | Subsidiary | More than one subsidiary or name of each subsidiary | Subsidiary | More than one subsidiary or name of each subsidiary | Parent or each subsidiary | [Parent name] and any of its subsidiaries |
| Copy of notice to | Parent only | Each subsidiary | Subsidiary | None | Subsidiary | None | Parent or each subsidiary | Parent only |