SCHEDULES

SCHEDULE 36Information and inspection powers

Part 4Restrictions on powers

Auditors and tax advisers: supplementary

26(1)Paragraphs 24(1) and 25(1) do not have effect in relation to—

(a)information explaining any information or document which the person to whom the notice is given has, as tax accountant, assisted any client in preparing for, or delivering to, HMRC, or

(b)a document which contains such information.

(2)In the case of a notice given under paragraph 5, paragraphs 24(1) and 25(1) do not have effect in relation to—

(a)any information giving the identity or address of a person to whom the notice relates or of a person who has acted on behalf of such a person, or

(b)a document which contains such information.

(3)Paragraphs 24(1) and 25(1) are not disapplied by sub-paragraph (1) or (2) if the information in question has already been provided, or a document containing the information in question has already been produced, to an officer of Revenue and Customs.