HMRC Investigations Handbook
Mark McLaughlin
HMRC Investigations Handbook
HMRC Investigations Handbook provides essential guidance on all aspects of HMRC's investigative work – special civil investigations, criminal prosecutions, self-assessment enquiries, VAT and customs visits, penalties and appeals. The practical advice, with reference to recent case decisions, covers how to prepare for interviews with HMRC, revenue information powers, tax appeals and settlement negotiations, plus vital information on the relationship between tax evasion and money laundering.
Of all the areas of tax law in the UK, the one that is arguably changing with the greatest frequency is that dealing with tax administration and compliance, and helps practitioners to keep up-to-date.
With contributions from a range of experts in their fields, the commentary is structured to follow the path of a potential investigation, and allows the reader to quickly find what they need.
The most recent update features the following:
- Commentary added in light of the changes to the Contractual Disclosure Facility (CDC) from 14 June 2023 (para 21.80)
- New commentary added on the ‘reasonably required’ test (para 5.36) with reference to recent cases such as Leen v HMRC [2023] UKFTT 00407 (TC), and Avonside Roofing Ltd v HMRC [2021] UKFTT 158 (TC)
- On the issue of whether discoveries can become stale, commentary added following the important Supreme Court decision in Revenue & Customs Comrs v Tooth [2021] UKSC 17 which confirmed that any delay in making the assessment after the officer discovers an insufficiency is irrelevant (para 4.48)
- New commentary on situations where HMRC will open an informal compliance check (para 8.30)