Is it an elephant?

KEY POINTS

• Treat informal enquiries with care.
• HMRC’s powers to request information formally.
• Taxpayers can ask for a formal enquiry notice.
• Advisers might be bypassed by HMRC officers.

What’s grey has four legs two large ears a tail and a trunk? Easy! Surely everyone knows the answer to that: we all know an elephant when we see one. But are all things what they at first seem? Take tax enquiries of the informal kind for example.

We have seen a few cases recently where HMRC officers have sought to ask ‘informal’ questions on tax return items.

This article considers how any general move towards a new non-statutory approach to self assessment enquiries might work in practice.

Practitioners familiar with the tax issues surrounding big companies and HMRC’s Review of Links with Large Business will...