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...
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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...
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