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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: rules that apply to all notices: accountants’ working papers: approach

You should not seek access to an accountant’s linking documents as a matter of routine. This is a very sensitive area and it should be approached with great care.

You are most likely to seek access to them where it is not possible to link the figures in the records to the figures in the accounts or returns.

Initially, following an informal approach, you would use the appropriate information powers to obtain the documents or particulars from the person.

Where papers contain both ‘linking information’ and audit matters or tax/duty advice, you are entitled to access the information showing how the entry in the accounts, return or information was arrived at. There is no entitlement to access those parts of the papers containing audit information or ‘relevant communications’ about tax advice.

Where an accountant claims protection for part of his papers he can give you a photocopy or other facsimile of the part which is not protected. If asked, he must make the original available for inspection, covering up the protected parts if he wishes. See CH22340.

You can obtain audit papers and relevant communications if

  • the auditor or tax adviser has assisted in the preparation or delivery to HMRC of any information, return, accounts or other document and
  • the audit papers or relevant communications contain workings or other analytical information showing how an entry within it was arrived at and
  • the relevant information has not previously been made available to HMRC.

Note: Even though you can obtain information showing how an entry was arrived at you cannot obtain information showing why the entry was arrived at in a particular way.

For example, a suspense account has been created in the trial balance of a business.

This allows the accounts to balance but cannot be reflected in the statutory accounts as the accounts need to be cleared and any entries corrected. You are allowed to require the journals within the accountant’s working papers which were created in order to clear and correct the suspense account. You are not allowed to require the discussion papers between the accountant and the person which outline how the suspense account arose initially.

Advise the accountant that you are willing to visit his office or the person’s premises to examine the papers and to take copies or extracts.

Complete all the procedures as speedily as possible

  • by the use of short BF periods and
  • by dealing with the case promptly at each stage.

The powers of access to accountant’s working papers do not override the other protections which apply, for example to

  • personal records, see CH22180 
  • journalistic material, see CH22220 
  • documents relating to the conduct of an appeal, see CH22160 
  • documents covered by legal professional privilege, see CH22240.