CH225595 - How to do a compliance check: information powers: third party notice: groups: summary table

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CH225520

CH225530

CH225540

CH225550

CH225560

CH225570

CH225580

CH225590

Notice to

External third party

External third party

Parent

Parent

Parent

Parent

Subsidiary

Subsidiary

To check tax postion of

Parent and one or more known subsidiaries

One or more known subsidiaries only

Parent and one known subsidiary

Parent and more than one known subsidiary

One known subsidiary

More than one known subsidiary

Parent or one or more known subsidiaries

Parent and one or more known subsidiaries

Type of notice

3 party

3 party

Combined taxpayer and 3 party

Combined taxpayer and 3 party

3 party

3 party

3 party

3 party

Para 21/21A conditions, see CH23520

No effect

No effect

Apply to parent but not subsidiary

Applies to parent and all subsidiaries unless each subsidiary is named. In which case it only applies to parent and the named subsidiaries

No effect

Applies to all subsidiaries unless each subsidiary is named. In which case it only applies to the named subsidiaries

No effect

No effect

Taxpayer approval required

Parent only

Each subsidiary

Subsidiary

None

Subsidiary

None

Parent or each subsidiary

Parent

Appeal grounds, if not tribunal approved

Too onerous only

Too onerous only

Any

Any

Too onerous only

Any

Too onerous only

Too onerous only

No appeal against

Statutory records of parent and each of its subsidiaries

Statutory records of each subsidiary

Statutory records of parent or the subsidiary

Statutory records of parent or any of its subsidiaries

Statutory records of subsidiary

Statutory records of parent or any of its subsidiaries

Statutory records of parent or each subsidiary

Statutory records of parent and each of its subsidiaries

Tribunal approval required

If no taxpayer approval

If no taxpayer approval

If no taxpayer approval

Optional

If no taxpayer approval

Optional

If no taxpayer approval

If no taxpayer approval

Opportunity to make representations

Recipient

Recipient

Recipient

Recipient

Recipient

Recipient

Recipient

Recipient

Summary of reasons

Parent only

Each subsidiary

Subsidiary

None

Subsidiary

None

Parent or each subsidiary

Parent

If tribunal, no appeal against

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Notice or any requirement in notice

Name  in notice

[Parent name] and any of its subsidiaries

Each subsidiary

Subsidiary

More than one subsidiary or name of each subsidiary

Subsidiary

More than one subsidiary or name of each subsidiary

Parent or each subsidiary

[Parent name] and any of its subsidiaries

Copy of notice to

Parent only

Each subsidiary

Subsidiary

None

Subsidiary

None

Parent or each subsidiary

Parent only