Documents belonging to auditor or tax adviser: information to be disclosedU.K.
27(1)This paragraph applies where a notice is given under Part 2 of this Schedule relating to a document that falls within paragraph 26 (documents belonging to auditor or tax adviser) but contains—U.K.
(a)information explaining any information, return or other document that the person to whom the notice is given has, as tax accountant, assisted any client of his in preparing for, or for delivering to, the officer or the Board, or
(b)in the case of a notice under paragraph 11 (notice in respect of unnamed taxpayer or taxpayers), information as to the identity or address of any taxpayer to whom the notice relates or any person who has acted on behalf of any such person,
that has not otherwise been made available to the Inland Revenue.
(2)For this purpose information is regarded as having been made available to the Inland Revenue if it is contained in some other document and—
(a)that other document, or a copy of it, has been delivered to the officer or the Board, or
(b)that other document has been inspected by an officer of the Board.
(3)Where this paragraph applies the person to whom the notice is given must, if he does not deliver the document or make it available for inspection in accordance with the notice—
(a)deliver to the officer (or, as the case may be, the Board) a copy (photographic or otherwise by way of facsimile) of any parts of the document that contain such information as is mentioned in sub-paragraph (1), and
(b)if so required by the officer (or, as the case may be, the Board), make available for inspection by a named officer of the Board such parts of the original document as contain such information.
(4)Failure to comply with any such requirement counts as a failure to comply with the notice.