Decided on penalties

KEEP YOUR FRIENDS close but your enemies closer! Perhaps this proverb draws an unkind unfair analogy with the relationship between HMRC and professional advisers particularly in this era of 'Working Together' and especially in a joint article between an HMRC Area Director and a tax adviser! However in the context of enquiry work involving disputes over issues of culpability and penalties tensions between tax professionals and HMRC can mount and communications can become adversarial. A clearer understanding of the 'other side's' position can help to alleviate such problems albeit that both parties may not necessarily agree at the end of the day.
Culpability in respect of technical adjustments in aspect company enquiry cases was the subject of a Working Together meeting held last year in Manchester. HMRC produced a number of case studies for discussion between professional advisers and HMRC officials. These were...