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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Conditions and safeguards: What we can require or inspect: Tax position

Tax position means a person’s position regarding any of the following

  • Income tax (including PAYE)
  • National Insurance contributions
  • Tax deducted under the Construction Industry Scheme
  • Capital gains tax
  • Corporation tax (including amounts treated as corporation tax)
  • VAT (including amounts treated as VAT)
  • Insurance premium tax
  • Inheritance tax
  • Stamp duty land tax
  • Stamp duty reserve tax
  • Petroleum revenue tax
  • Aggregates levy
  • Climate change levy
  • Landfill tax
  • Bank payroll tax
  • Annual tax on enveloped dwellings, and
  • Relevant foreign tax, see CH21560.

A tax position includes

  • a person’s past, present and future liability to pay any of the above taxes
  • penalties and other amounts payable or that may be payable in connection with tax
  • claims, elections, applications and notices in connection with tax, and
  • deductions or repayments of tax that the person is required to make under

    • the PAYE Regulations,
    • the Construction Industry Scheme Regulations, or
    • any other provisions of the Taxes Acts.

Note that if your compliance check is into an excise duty, you will use powers under CEMA79. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

FA08/SCH36/PARA63 & 64

SSAA92/S110ZA

FA10/SCH1/PARA36(1)

CEMA79/S118BA