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Finance Act 2012

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16(1)A file access notice does not require the document-holder to provide a relevant document if—

(a)the whole of the document originated before the back-stop day, and

(b)no part of it has a bearing on tax periods ending on or after that day.

(2)“The back-stop day” is the first day of the period of 20 years ending with the day on which the file access notice is given.

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