Key points
- HMRC has various powers that it can use to investigate a taxpayer.
- Information can be requested informally or using FA 2008 Sch 36.
- The tribunal must be satisfied HMRC is justified in issuing an information notice.
- Different ways of concluding an enquiry.
- Always meet the deadlines for appeals.
Dealings with HMRC come in all shapes and sizes. Some can be as simple as a telephone call whereas more complex matters to paraphrase Malcolm Tucker in the BBC’s The Thick of It can be as long as a Leonard Cohen song. Some enquiries can span several years before they are finally closed.
This article covers some of the relevant legal principles and HMRC’s practice which are important to understand when handling an enquiry or investigation for a client. Note we do not cover VAT or specialised investigations such as the code of practice 9...