CH225620 | How to do a compliance check: information powers: third party notice: partnerships: notice to external third party to check more than one partner

If you are giving a notice to a third party who is a person other than a partner, for the purpose of checking the tax position of more than one partner in their capacity as partners, see CH23680, the following rules apply.

• The notice need only state that it is for checking the tax position of more than one partner. It need then name only the partnership. It does not need to name the individual partners. This enables you to avoid having to make unnecessary (and possibly incomplete) lists of partners. But where listing the partners is likely to help the recipient to comply with the notice, you should do so. You should also name the affected partners in your description of documents and information where this helps to identify what you are seeking.

• If you decide to obtain the approval of the person rather than the tribunal’s approval, you only need to obtain the approval of one partner. This would normally be the partner responsible for the partnership return.

• Only one partner needs to be given a copy of the notice.

• If the notice is to be approved by the tribunal, only one partner needs to be given a summary of the reasons why the information and documents are required, see CH24160. It may be appropriate to seek tribunal approval where you need to protect your information from premature exposure at an appeal hearing on the notice.