Does HMRC have too many powers, or not enough?

The taxes collected by HMRC – £584.5bn in 2020-21 – run the UK and as such it is essential that the right amounts are collected.

To this end HMRC has a myriad of powers to review returns and check taxes have been correctly calculated and paid. For civil cases these powers include the ability to:

• open and close enquiries;
• request information and documentation;
• inspect business premises; and
• raise assessments for up to 20 years.

Most people will agree the powers are not ‘bad’ but the way they are used affects how they and HMRC are perceived. Unfortunately many tax investigations practitioners will have experienced HMRC applying its powers incorrectly or even abusing them.

HMRC’s most recent review of its powers Evaluation of HMRC’s implementation of powers obligations and safeguards introduced since 2012 was published...