Richard Clarke and Jennifer Knowlson of PricewaterhouseCoopers LLP's Tax Investigations network discuss an apparent change of HMRC policy on closing enquiries
When income tax self-assessment was introduced in 1997 HMRC was given the automatic right to enquire into a client's tax return without having to give reasons for doing so. This was a break with the previous practice under which investigators had to say why they wanted to ask questions about a return (as they were operating under the old discovery assessment provisions). The counter-balancing safeguard that was introduced by self-assessment was the taxpayer's right to ask for closure of the enquiry. If HMRC closed the enquiry but did not agree with the self-assessment made it had to state its conclusions so that the taxpayer could appreciate why HMRC had taken...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Richard Clarke and Jennifer Knowlson of PricewaterhouseCoopers LLP's Tax Investigations network discuss an apparent change of HMRC policy on closing enquiries
When income tax self-assessment was introduced in 1997 HMRC was given the automatic right to enquire into a client's tax return without having to give reasons for doing so. This was a break with the previous practice under which investigators had to say why they wanted to ask questions about a return (as they were operating under the old discovery assessment provisions). The counter-balancing safeguard that was introduced by self-assessment was the taxpayer's right to ask for closure of the enquiry. If HMRC closed the enquiry but did not agree with the self-assessment made it had to state its conclusions so that the taxpayer could appreciate why HMRC had taken...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
