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Official guidance
Specialist Investigations Operational Guidance

SIOG7200 · Information and inspection powers: Schedule 36 FA 2008

  • SIOG7201 · Transitional - use of new powers in pre-existing enquiries
  • SIOG7205 · Taxpayer information notices after assessments or closure notices have been issued
  • SIOG7206 · Taxpayer information notices after assessments or closure notices have been issued - avoiding premature action
  • SIOG7207 · Taxpayer information notices after assessments or closure notices have been issued - tribunal directions
  • SIOG7210 · Scope of ‘documents’
  • SIOG7220 · Opportunity letters
  • SIOG7221 · Opportunity letters and informal requests
  • SIOG7230 · Summary of reasons
  • SIOG7240 · Reasons not to be given
  • SIOG7245 · Third party notices concealed from the taxpayer
  • SIOG7250 · Templates and outlines
  • SIOG7260 · Records to be kept
  • SIOG7270 · Delivery of a notice to a large firm or company
  • SIOG7275 · Third party enquiries - removing references to 'fraud' and 'crime'
  • SIOG7280 · Non-compliance with a third party notice
  • SIOG7290 · Identity unknown notices
  1. Information and inspection powers: Schedule 36 FA 2008: contents
  2. Information and inspection powers: Schedule 36 FA 2008: opportunity letters

SIOG7220 | Information and inspection powers: Schedule 36 FA 2008: opportunity letters

From HM Revenue & Customs · Specialist Investigations Operational Guidance

In order to ensure that an ‘opportunity letter’ issued under paragraph 3(3)(c) covers all of the ground, it is best practice to draft the description of information and document it as if it were for the formal notice. The subsequent notice may be altered for clarity or drafted more narrowly to reflect representations received, but it must not be drafted more widely.

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