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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Human Rights Act: Article 6: Taxpayer refuses to co-operate

If the taxpayer decides not to answer any questions or co-operate after being given the advice at EM1364, and you need to obtain further information or documents to enable you to establish any additional liabilities to tax, you will have to use your formal powers (for example under FA08/Sch36/Para1).

If ultimately the case proceeds to a tribunal hearing you must make an early penalty determination or assessment, see EM5202 so that any appeal against it can be heard at the same hearing.