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PART 4INVESTIGATORY POWERS OF WRA

CHAPTER 2POWERS TO REQUIRE INFORMATION AND DOCUMENTS

87Third party notices

(1)WRA may issue a notice (a “third party notice”) requiring a person to provide information or produce a document if—

(a)WRA requires the information or document for the purpose of checking the tax position of another person (“the taxpayer”) whose identity is known to WRA,

(b)it is reasonable to require the person to provide the information or produce the document, and

(c)nothing in sections 97 to 102 prevents WRA from requiring the person to provide the information or produce the document.

(2)But WRA may not issue a third party notice without—

(a)the agreement of the taxpayer, or

(b)the approval of the tribunal.

(3)The taxpayer to whom a third party notice relates must—

(a)be named in the notice, and

(b)be issued with a copy of the notice by WRA.

(4)But when it approves a third party notice, the tribunal may disapply one or both of the requirements of subsection (3) if it is satisfied that WRA has grounds for believing that naming the taxpayer or, as the case may be, issuing the taxpayer with a copy of the notice might seriously prejudice the assessment or collection of devolved tax.