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You will normally gather the documents and information you need to check the tax position of a member of a group using either a taxpayer notice, see CH23520, or a third party notice, see CH23620. There are no changes or relaxations to the rules where you ask for documents or information relating to a particular group member.

Sometimes the document or information you obtain, either voluntarily or as a result of an information notice, will be useful to check the tax position of another group member. CRCA05/S17 allows you to use that document or information in your check of the other member.

There are special rules where you issue a third party notice to

• any person for the purpose of checking the tax position of the parent undertaking and any of its subsidiary undertakings, see CH23760, or
• the parent undertaking for the purpose of checking the tax position of more than one of its subsidiary undertakings, see CH23780.

There are no special rules for a third party notice issued to a parent undertaking for the purpose of checking the tax position of one of its subsidiary undertakings. You must follow the guidance in CH23620.

There are no special rules for a third party notice issued to a subsidiary undertaking for the purpose of checking the tax position of the parent undertaking or any fellow subsidiaries. You must follow the guidance in CH23620.

An undertaking is a body corporate, a partnership or an unincorporated association carrying on a trade or business, with or without a view to profit.

A parent undertaking or a parent undertaking’s subsidiary, see CH23800, is determined using the rules in Section 1162 of the Companies Act 2006.

CH23800 explains in more detail the meaning of ‘parent undertaking� and ‘subsidiary undertaking�.

FA08/SCH36/PARA35

Companies Act 2006/S1161