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Do HMRC have a valid reason for an enquiry?
I have recently acquired a client who has several international jobs. As a result he has bank accounts in several countries to receive his salaries. One is in Switzerland so he has had to make declarations to the bank and to HMRC that his UK tax affairs are in order.
He has received a compliance check letter asking for details of all his foreign accounts and interests in trusts abroad going back to 2008.
I am confident that he has always done his best to disclose everything but because he is a new client I do not have the records to comply with this request. In the absence of any indication that he has omitted anything anywhere it seems an unreasonable request.
As far as I can see FA 2008 Sch 36 para 21 allows a taxpayer notice only in respect of years...
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