We are unable to issue a file access notice without the approval of the tribunal.

The tribunal can approve a file access notice where

the application for approval is made by, or with the agreement of, an authorised officer, see CH882700

the tribunal is satisfied that the case falls within a Case A or Case B situation, see CH182540

the tribunal is satisfied that, in the circumstances, the officer giving the notice is justified in doing so

the document-holder and, where different, the tax agent, have been told that relevant documents are to be required and they have been given a reasonable opportunity to make representations to us, see CH882530, and

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