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ALEX BYRNE looks at some recent worrying traits in HMRC's investigation work
KEY POINTS
- HMRC's wish to review private financial details
- A case study
- The relevance of Working Together and COP 14
- The issue of a notice under TMA 1970 s 20
- Do advisers have any defence to a s 20 notice?
- Is use of s 20 counter productive?
If I were to compile a top ten of issues in investigation cases number one would be HMRC requests for private bank accounts. (Number two would be requests for accountants working/link papers.)
The position agreed with HMRC on requests for private bank accounts is set out in Working Together 12 and this is that private bank statements will not be requested as a matter of course at the outset of an enquiry (see the extracts from Working Together 12 and 8...
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