SCHEDULES

SCHEDULE 38Tax agents: dishonest conduct

PART 3Power to obtain tax agent’s files etc

16Old documents

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.