Notice to |
external third party |
external third party |
partner whose tax position is not being checked |
partner whose tax position is not being checked |
partner whose tax position is being checked |
partner whose tax position is being checked |
To check tax position of |
more than one partner in their capacity as partners |
one partner |
more than one partner in their capacity as partners |
one partner |
more than one other partner in their capacity as partners |
one other partner in their capacity as partner |
Type of notice |
3rd party |
3rd party |
3rd party |
3rd party |
combined taxpayer & 3rd party |
combined taxpayer & 3rd party |
Para 21/21A conditions - see CH23520
|
no effect |
no effect |
no effect |
no effect |
recipient partner only |
recipient partner only |
Taxpayer approval required |
at least one partner |
partner |
none |
none |
none |
none |
Appeal grounds unless tribunal-approved |
too onerous only |
too onerous only |
any |
any |
any |
any |
No appeal against |
statutory records of any of the partners |
statutory records of the partner |
statutory records of any of the partners |
statutory records of the partner |
statutory records of any of the partners |
statutory records of any of the partners |
Tribunal approval required |
if no taxpayer approval |
if no taxpayer approval |
optional |
optional |
optional |
optional |
Opportunity to make representations |
recipient |
recipient |
recipient |
recipient |
recipient |
recipient |
Summary of reasons to |
at least one partner |
partner |
none |
none |
none |
none |
If tribunal-approved, 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 |
Name in notice |
‘more than one partner in the [partnership name] partnership’ |
partner |
‘more than one partner in the [partnership name] partnership’ |
partner |
‘more than one partner in the [partnership name] partnership’ |
partner |
Copy of notice to |
at least one partner |
partner |
none |
none |
none |
none |