An HMRC officer can issue a notice requiring a taxpayer to provide information or produce documents that the officer 'reasonably requires' for the purposes of checking that taxpayer's 'tax position'. However, there are protections, and HMRC information notices can be challenged.
HMRC gets many of its significant leads from informants. When people fall out, be that business partners or spouses, they often tend to view telling the tax authority as a dish best served cold. An informant’s phone call or email gives HMRC inspectors insights that no database ever could.
Managing HMRC investigations, and when to request their closure is about finding the right balance between cooperation and direction. There can be an art to responding to power.
HMRC have started to issue letters in relation to the Pandora Papers asking the recipients to review their tax affairs- any recipients should obtain professional advice.
Whatever emerges after next year’s General Election, there will be disputes around UK tax domicile claims for years to come. However, the approach taken by the Courts towards witness evidence in tax disputes has already changed, and so therefore must the advice given to clients.
HMRC’s review of COP9 is continuing and there may be further developments in Q4 of 2023. The COP9 process remains an opportunity to put things right and, if well handled, is often the best framework for taxpayers to resolve deliberate tax understatements. However, where the opportunity to make full disclosure is not taken, or a COP9 is mishandled, it is clear that the risks of criminal prosecution are increasing.
HMRC doesn’t need to look for signs of letting income- it already has the data.
HMRC is launching a new campaign in September 2022 to tackle non-compliance linked to offshore corporates owning UK properties.
UK taxpayers with connections to Euro Pacific would do well to take specialist advice urgently: HMRC already knows who they are
Tough disputes with HMRC can be necessary, but understanding all the options is key to resolution. How do you find the right path?
Where HMRC suspects serious tax evasion, its normal course is to investigate under “COP9”. What are the risks for clients and their advisers?
The Supreme Court’s judgement in Tooth was one of the more significant tax decisions of 2021, and will shape future interpretation of HMRC’s assessing powers
HMRC has committed to producing new guidance by summer 2021 on its approach to penalties.
HMRC are targeting non-doms for investigation. HMRC information requests and enquiries can drag on for years. Do recent Tribunal decisions provide guidance?
Managing tax risks goes well beyond the annual return process. How can you persuade HMRC that all is in good order. What if it isn’t?
HMRC requests for information and records can be extensive. What are HMRC’s powers, and how can the process be managed?
In 2018 alone HMRC received 5.67 million records on UK taxpayers’ offshore financial accounts. How does it use this information?
