CH882750 - Agent operational guidance: dishonest tax agents: getting access to an agent’s files: file access notice: applications to the tribunal
A file access notice can only be issued after the tribunal has given their approval, see CH182680.
Detailed technical guidance about making applications to the tribunal starts at ARTG7500. There is also operational guidance about making applications to the tribunal at CH265000.
The tax agent and, if different, the document-holder may make representations to you, see CH882550. They may also make representations to the tribunal and attend the hearing.