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HMRC internal manual

Compliance Handbook

How to do a compliance check: general: customers requiring extra support

Where you have concerns that a person may be vulnerable because of their age or personal circumstances then you should consider their needs for extra support.

There isn’t a typical ‘vulnerable’ customer, and people who others see as vulnerable may not consider themselves in that way. However, factors like age, physical or mental health, caring responsibilities and life changing events such as redundancy, relationship breakdown or bereavement could mean someone is put in a vulnerable position. Sometimes it may be a temporary situation, but they could need extra support as a result and we should try to provide this.

The health and safety of customers should always be considered during a compliance check. Guidance at COG11400 advises on the action you should take if a customer

  • becomes ill
  • behaves violently or irrationally or
  • threatens suicide

during a visit, telephone call or meeting.

Young people (aged under 18) are personally responsible for their tax affairs and are liable to pay their tax in the same way as other customers, however because of their age you must take extra care when discussing their tax affairs with them, see CH201350.

If a person has indicated that they have a physical or mental impairment then you should refer to the guidance at COG11355 for details of how to help.

For all other customers who may be temporarily vulnerable due to illness or short term crisis or difficulty you should consider how you can provide them with the additional help they need.

You should remind yourself of the services available for people with particular requirements, see COG11380 and Dealing with HMRC if you have particular needs.

Reasonable adjustments

If a person has explained that they need additional help you may need to agree any reasonable adjustments they require and include a timetable for key stages of any compliance work. You would not normally question the adjustments providing they are reasonable and allow you to progress your compliance check. If you do not think the adjustments are reasonable you should ask how they will help the person participate in the compliance check.

Guidance at COG11345 explains how you should note customer records with details of any particular needs and adjustments required. Record the reasonable adjustments you have agreed on Caseflow, Self Assessment Notes, or in any other system you are working on. You must take particular care that all notes are clear and concise.

Third party support

A person may wish a third party to provide emotional support or assist them in their communications with you during the course of the compliance check or in a meeting. The third party may not be appointed to deal with their tax affairs but will be privy to personal and confidential information.

The third party may be

  • a friend, relative or carer
  • from a voluntary organisation
  • any of the health sector or social care professionals
  • a support worker.

The guidance at IDG30210  specifies that you should obtain written consent during meetings, but you do not need to ask the person for written consent if you think it will cause further stress. You must check whether the person has freely given their consent to the third party being present and only continue with the meeting if you are satisfied that they have done so.

Record in your notes of meeting or notebook

  • the name of the third party
  • the fact that their presence was there to aid communication or support the person and was not acting as an agent, and
  • that the person had freely given their consent to the third party’s presence.

Customer Zone

There is a lot of information contained within this site. Items of particular note: