Paragraph 11 I1

in sub-paragraph (1), after “may” insert “, subject to sub-paragraph (1A),”;

after sub-paragraph (1) insert—

“(1A)

In a case falling within case A (see paragraph 7), a file access notice may only require the provision of relevant documents relating to clients of the tax adviser with respect to whom the authorised officer of Revenue and Customs mentioned in paragraph 7(2) has reasonable grounds to suspect the tax adviser is engaging in or has engaged in sanctionable conduct.

(1B)

In a case falling within Case A (see paragraph 7), a file access notice—

(a)

must identify the clients of the tax adviser (in relation to whom relevant documents are required to be provided), and

(b)

may identify those clients by reference to a class or description of clients.”;

in sub-paragraph (2)—

in sub-paragraph (3), for “agent” (in each place it occurs) substitute “adviser”.