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HMRC internal manual

Compliance Operational Guidance

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HM Revenue & Customs
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Supporting Guidance: business records checks: follow-up visits: visiting officer action

In all cases where you find that the business has inadequate statutory business records during your initial visit, you must carry out a follow-up visit. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

    • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
    • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Key elements of the BRC follow-up programme are:

  1. All visits where you have categorised records as inadequate during the initial visit must be submitted to your manager who should consider a follow-up visit.
  2. Follow-up visits will normally only look at the areas where weaknesses in record-keeping were identified at the original visit, and will not include a further complete look at the records.
  3. In most cases a follow-up visit should take less time than the original visit. An exception to this rule will be where there were no, or very few, records at the initial visit and these have now been improved or introduced in line with guidance you have given. In these circumstances a full BRC check is necessary to judge the adequacy of these new records.

You should reconfirm the necessary arrangements to undertake a follow-up check by

  • contacting the customer by telephone to confirm the visit or to confirm an alternative follow-up method, where covered by one of the exceptions above
  • issuing the follow-up visit confirmation letter BRC6 or a follow-up alternative BRC6A (available in SEES), depending on how the follow up activity is to be carried out
  • issuing a copy of the follow-up letter to the agent (if applicable)
  • updating your calendar with the visit details.

You must recognise that a further visit may be disruptive to the customer. You must handle any concerns raised sympathetically, whilst ensuring that the follow-up visit is carried out effectively.

Things to consider

Follow-up visits are not a full visit programme for all customers identified as having inadequate business records.

Only cases identified at the initial visit as inadequate require a follow-up visit.

You should complete the BRC follow-up visit before referring the case to RIS for a tax check.

A RIS referral should be made via your manager in appropriate cases, regardless of whether a record keeping penalty is charged. If there is significant tax at risk for earlier years, any behavioural change will in the current period mitigate the record keeping penalty, but not change the need for a compliance check to review the accuracy of the earlier returns.

Managers should follow the guidance at COG941175 to minimise any delay in resolving the record keeping penalty position.