Revenue Powers

THE CLIMATE IN which the Inland Revenue exercises its investigatory powers has undergone significant developments over the last few years. The Revenue's actions are subject to ever greater scrutiny as a result of the enactment of legislation such as the Human Rights Act 1998 the Data Protection Act 1998 and the Regulation of Investigatory Powers Act (RIPA) 2000. At the same time the Revenue's ability to share information with overseas authorities has increased as a result of the implementation of the Mutual Assistance Directive and the signing in April 2004 of a memorandum of understanding between the revenue authorities of the UK the US Australia and Canada for the creation of a Joint International Tax Shelter Information Centre.

In this article we examine the practical effect which these measures have had and some of the steps which the Revenue has taken to ensure...