HMRC’s terminology has changed over the past few years and the familiar term “Enquiry” has been replaced by the robotic language of “Compliance Checks”, which could easily be used to describe a process devoid of any human involvement.
More importantly, whatever HMRC chooses to call its interventions, the Enquiry framework has changed dramatically over the same period as well, with HMRC acquiring enhanced information gathering powers and the right to impose ever more draconian penalties.
Nevertheless, as professional advisers we must remain alive to fundamental issues such as the scope of information requests made by HMRC, the closure of Enquiry windows, the validity of Discovery assessments and requests for meetings with our clients to highlight just four areas of potential “non-alignment”. These are all topics on which we can provide you with guidance and support.
We can also provide you with the following practical assistance on the Enquiry front: drafting written responses to formal HMRC correspondence, engaging proactively with the Officer concerned and seeking mitigation of penalties (if relevant), all with the aim of bringing matters to a satisfactory conclusion without the need for eye wateringly expensive tax litigation.
Experience has shown that our input can be extremely valuable in situations involving an apparent deadlock or stalemate. If requested, we can assume conduct of the case on your client’s behalf. Whilst the benefit might not be immediately obvious, we’ve found that the simple step of bringing in specialist tax advisers can often have a dramatic psychological impact on the conduct of an Enquiry. At the very least, it sends out a clear message that you and your client have no intention of throwing in the proverbial towel.
Whether you’ve reached an impasse or you’re simply looking for guidance on a specific aspect of an Enquiry, we’re always happy to discuss how we can support you, so please do get in touch with us.