CH882520 | Agent operational guidance: dishonest tax agents: getting access to an agent’s files: file access notice: who we can give a notice to
From HM Revenue & Customs · Compliance Handbook
You can give a file access notice to a tax agent who has been
given a conduct notice and any appeal has been confirmed in your favour, or the time limit to appeal has expired
convicted of an offence of fraud or dishonesty in relation to tax
and, in relation to those tax agents,
any other person (a third party) that you believe holds documents.
The person you give the notice to is the ‘document-holder’.
The notice requires the person to provide ‘relevant documents’, see CH182600.