The heavy mob gets heavier

TAX INSPECTORS WERE widely adopting an enabling approach the last time we reported on corporation tax self assessment. Since the introduction of corporation tax self assessment the PricewaterhouseCoopers tax investigations team has examined enquiry trends in two previous Taxation articles ('Trouble with corporate tax self assessment?' 17 January 2002 page 359 and 'More trouble?' 26 February 2004 page 509). But what new trends are now emerging in the thousands of enquiry notices we see each year?

Tighter time limits

With an informal request for information the enquiry legislation does not specify a time limit for compliance. However it has become increasingly common for HMRC to set a deadline for submission of the information requested.
In 2002 we reported that 47% of enquiry notices carried an information provision deadline. In the past 12 months 85% of the information requests we reviewed had a...