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.