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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
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Information Powers: TMA70/S20: Accountant's Working Papers: Definitions

Working Papers

You should never ask to see the full ‘working papers’ of an accountant.

These are likely to be extensive and will almost certainly contain documents you are not entitled to ask for. That is not to say that you should decline any offer, voluntarily made, to see an accountant’s full working papers, but such an offer will be exceptional.

Auditor’s Papers

Auditor’s papers are papers that are the property of an auditor appointed under a statutory provision (for example, the Companies Act or the Building Societies Act) and which have been prepared by or for him to enable him to carry out his duties as an auditor.

This definition is extended to papers that are the property of an accountant appointed under a contractual obligation to carry out a non statutory, third party, independent audit. This work must be distinct from that relating to the preparation of accounts and for a Companies Act audit. Examples are an audit under the terms of a partnership deed or the rules of a professional body.

You are not entitled to request audit papers except as explained below

Tax Adviser’s Relevant Communications

A tax adviser is any person appointed either directly by his client or indirectly through another tax adviser, to give advice on the client’s tax affairs.

Relevant communications are the property of the tax adviser concerned. They are communications between a tax adviser and his client (or another tax adviser of the client) made for the purposes of giving or obtaining advice about the client’s tax affairs. It includes such things as letters, e-mails, internal memoranda, faxes and notes of meetings or telephone conversations.

You are not entitled to request relevant communications except as explained below

When you can see audit papers and relevant communications

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.

Link documents contain information, which provides the link between the taxpayer’s books and records and the accounts, return or other information submitted to HMRC. They show what adjustments the accountant made to the figures in the prime records and explain how the figures appearing in the final accounts, return or information came into being.

In many small businesses with incomplete records (perhaps comprising no more than a sheaf of bank statements and a bundle of invoices) the accountant’s linking documents may become documents that the client is legally entitled to retain and thus become, in effect, part of the records of the business.