Numerous practical difficulties arise from Sch 36; Phil Berwick highlights the five most common and explains how to deal with them.
HMRC’s information powers contained in FA 2008 Sch 36 are a powerful weapon in the investigating officer’s armoury. This article considers five issues that can arise in practice when dealing with information requests from an HMRC officer under those provisions. The article assumes that the information request has been issued in the context of a HMRC enquiry into a tax return.
1. Formal or informal?
HMRC officers usually start with an informal request for information. It is only if the taxpayer fails to co-operate with the informal approach that the officer will issue a formal request. When an HMRC officer issues an informal request the items contained therein should be viewed in the light of the Sch 36 provisions. A key aspect of managing a...
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Numerous practical difficulties arise from Sch 36; Phil Berwick highlights the five most common and explains how to deal with them.
HMRC’s information powers contained in FA 2008 Sch 36 are a powerful weapon in the investigating officer’s armoury. This article considers five issues that can arise in practice when dealing with information requests from an HMRC officer under those provisions. The article assumes that the information request has been issued in the context of a HMRC enquiry into a tax return.
1. Formal or informal?
HMRC officers usually start with an informal request for information. It is only if the taxpayer fails to co-operate with the informal approach that the officer will issue a formal request. When an HMRC officer issues an informal request the items contained therein should be viewed in the light of the Sch 36 provisions. A key aspect of managing a...
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:
