PART 4

INVESTIGATORY POWERS OF WRA
CHAPTER 2

POWERS TO REQUIRE INFORMATION AND DOCUMENTS

Requiring information and documents in relation to a group of undertakings
90
1
This section applies where an undertaking is a parent undertaking in relation to another undertaking (a “subsidiary undertaking”).
2
Where a third party notice is issued to any person for the purpose of checking the tax position of a parent undertaking and any of its subsidiary undertakings—
a
the references in sections 87(2)(a), (3) and (4) and 88(3)(d) to the taxpayer have effect as if they were references to the parent undertaking, and
b
section 87(3) is to be treated as also requiring the notice to state its purpose.
3
Where a third party notice is issued to a parent undertaking for the purpose of checking the tax position of more than one subsidiary undertaking—
a
the notice must state its purpose,
b
sections 87(2)(a) and (3) and 88(3)(d) do not apply, and
c
section 100 (taxpayer notices following a tax return) applies as if the third party notice were a taxpayer notice issued to each subsidiary undertaking (or, if the third party notice names the subsidiary undertakings to which it relates, to each of those undertakings).
4
In this section, “parent undertaking”, “subsidiary undertaking” and “undertaking” have the meanings given in section 1162 of, and Schedule 7 to, the Companies Act 2006 (c. 46).