In cases of serious fraud, a circuit judge (England) or a county-court judge (Northern Ireland), having considered information on oath presented by an authorised HMRC officer that:

there are reasonable grounds for suspecting that an offence involving serious fraud in relation to SDLT has been or is about to be committed and

that documents may be required as evidence in any proceedings in respect of such an offence and that those documents are or may be in the power or possession of any person,

may make an order (a ‘para. 32 order’) requiring the production of those documents, with a time limit for compliance of no more than ten working days

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