Finance Act 2003

6 (1) An authorised officer of the Board may for the purpose of enquiring into the tax liability of any person (“the taxpayer”) by notice in writing require any other person— U.K.

(a) to deliver to the officer, or

(b) if the person to whom the notice is given so elects, to make available for inspection by a named officer of the Board,

such documents as are in that person’s possession or power and (in the officer’s reasonable opinion) contain, or may contain, information relevant to any tax liability to which the taxpayer is or may be, or may have been, subject, or the amount of any such liability.

(2) An “authorised officer of the Board” means an officer of the Board authorised for the purposes of this Part of this Schedule.

(3) Before a person is given a notice under this paragraph he must be given a reasonable opportunity to deliver or make available the documents in question. No application for consent under paragraph 7 shall be made unless he has been given that opportunity.

(4) The persons who may be treated as “the taxpayer” for the purposes of this paragraph include a company that has ceased to exist and an individual who has died.

But a notice in relation to a taxpayer who has died may not be given more than six years after his death.