HMRC enquiries and compliance checks

Dealings with HMRC come in all shapes and sizes. Some can be as simple as a telephone call whereas more complex matters to paraphrase Malcolm Tucker in the BBC’s The Thick of It can be as long as a Leonard Cohen song. Some enquiries can span several years before they are finally closed.

This article covers some of the relevant legal principles and HMRC’s practice which are important to understand when handling an enquiry or investigation for a client. Note we do not cover VAT or specialised investigations such as the code of practice 9 procedure used in cases of suspected fraud.

Overview of HMRC’s powers

HMRC has a wide range of powers in its armoury. The main ones broadly are:

• to enquire into a return;
• to make a compliance check;
• to obtain information; and
• to make a discovery.

Enquiring into a return ...