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HMRC’s powers, penalties and safeguards under review

18 March 2024 / Steven Pinhey
Issue: 4929 / Categories: Comment & Analysis , HMRC powers , penalties , Admin
Powers review

Key points

  • The government has been reviewing HMRC’s powers and safeguards since 2005.
  • Latest consultation is setting out objectives and options for future implementation.
  • Should HMRC’s current enquiry and assessment powers be replaced with a single set of powers that would apply across all taxes?
  • Penalties could be based on the taxpayer’s co-operation in correcting matters with no behavioural element.
  • Various considerations on how to improve the statutory review process.

On 15 February HMRC published a call for evidence on its enquiry and assessment powers penalties and safeguards (

HMRC has said it is keen to ‘provide greater certainty and consistency bolster compliance and ultimately help support trust in the tax system’ and believes that this can be attained in part by reforming their enquiry and assessment powers penalties and safeguards.

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