The opening shots

THE PURPOSE OF this series of articles on self-assessment enquiries is not to consider the law except peripherally as necessary but to concentrate on the more practical aspects. Experience suggests that many tax practitioners are either not aware of their clients' rights or are reluctant to enforce them. I will concentrate on income tax for convenience but broadly speaking the following comments will apply equally to corporation tax enquiries although the statutory context to the two is not completely identical.

The opening letter

Like any enquiry this series starts with the opening letter. The first thing to realise is that the letter is not part of the statutory scheme of self assessment; it is an extra-statutory HMRC procedure. As such there are no statutory rules governing it and no statutory requirements connected with it. Nevertheless it needs to be approached in the...