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HMRC disclosures: doing the detective work

17 June 2024 / Matthew Watkins
Issue: 4941 / Categories: Comment & Analysis , HMRC powers , penalties , Compliance
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Detective work

Key points

  • HMRC needs to ensure that the correct amounts of tax have been paid and it has formal powers under FA 2008 to request information and documents from taxpayers.
  • There are only five scenarios where HMRC is able to make an information request under FA 2008 Sch 36.
  • HMRC may issue five different types of notice – readers will most commonly see taxpayer notices and third-party notices.
  • For practitioners whose clients receive HMRC notices it is advisable that they review each request critically and identify those which fail the test of clarity and precision.
  • What does ‘reasonably required’ in FA 2008 Sch 36 para 1 mean?
  • Failure to provide the information requested within the set timeframe can lead to financial penalties for non-compliance.

HMRC’s ability to check that a taxpayer has paid the correct amount of tax is critical to the successful operation of our tax...

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