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The implications of the First-tier Tribunal’s decision in Gold Nuts.
KEY POINTS
- HMRC can pursue a criminal or civil line of enquiry when investigating tax fraud.
- A disclosure under the contractual disclosure facility is an admission of fraud.
- The First-tier Tribunal decided it did not have the jurisdiction to close a COP9 enquiry.
- The right to refuse to respond to a Sch 36 notice.
- Potentially incriminating evidence must be disclosed at an early stage of an enquiry.
When HMRC suspects fraud or uses its extensive information-gathering powers practitioners and their clients may feel overwhelmed and alarmed. The department’s powers in these areas are often taken for granted and the receipt of a letter explaining that HMRC is investigating under code of practice 9 (COP9) or issuing information notices can put the recipient at a distinct disadvantage and on...
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