4

Where a third party notice is given to the parent undertaking for the purpose of checking the tax position of more than one subsidiary undertaking—

a

paragraph 2(2) only requires the notice to state this, and

b

the references in paragraph 3(5) to naming the taxpayer are to making that statement.

4A

In relation to such a notice—

a

in paragraph 3 (approval etc of notices), sub-paragraphs (1) and (3)(e) do not apply,

b

paragraph 4(1) (copying third party notices to taxpayer) does not apply,

c

paragraph 21 (restrictions on giving taxpayer notice where taxpayer has made return) applies as if the notice was a taxpayer notice or taxpayer notices given to each subsidiary undertaking (or, if the notice names the subsidiary undertakings to which it relates, to each of those undertakings),

d

paragraph 30(1) (appeal) has effect as if it permitted an appeal on any grounds, and

e

in paragraph 30(2) (no appeal in relation to taxpayer's statutory records), the reference to the taxpayer has effect as if it were a reference to the parent undertaking or any of its subsidiary undertakings.

—

a

sub-paragraphs (3) and (4) of that paragraph (approval of tribunal) have effect as if they permitted, but did not require, the officer to obtain the approval of the tribunal, and

b

paragraph 31 (appeal) has effect as if it permitted an appeal on any grounds, but the parent undertaking may not appeal against a requirement in the notice to produce any document that forms part of the statutory records of the parent undertaking or any of its subsidiary undertakings.