Finance Act 2003

Documents originating more than six years before date of notice

24 (1) A notice under Part 2 of this Schedule does not oblige a person to deliver or make available a document the whole of which originates more than six years before the date of the notice.

(2) Sub-paragraph (1) does not apply where the notice is so expressed as to exclude the restrictions of that sub-paragraph.

(3) A notice may only be so expressed if—

(a) in the case of a notice given by an authorised officer, the General or Special Commissioner giving consent to the notice has also given approval to the exclusion;

(b) in the case of a notice given by the Board, they have applied to a General or Special Commissioner for, and obtained, that approval.

(4) Approval shall only be given if the Commissioner is satisfied, on application by the officer or the Board, that tax has been, or may have been, lost to the Crown owing to the fraud of the taxpayer.