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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
Updated
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Working the Enquiry: general approach

You should normally open SA enquiries in a neutral way by asking for the information you require, without challenging the accuracy of the return. Wherever possible you should also explain what risks have been identified in order to establish openness and early dialogue with the taxpayer.

If you hold any third party information, you must follow the guidance at EM1895, before you disclose any of this to the taxpayer.

You should encourage the taxpayer to disclose any errors or concerns they may have and take an active part in quantifying them before you consider the use of information and inspection powers, see CH20000.

Once you have examined the information and documents provided by the taxpayer in reply to your initial request for information, you will need to consider whether there are matters that need further enquiry of whether you have any reason to believe the return may be inaccurate.

Where you believe that the return may be inaccurate you need to consider how to give the taxpayer the opportunity to disclose and co-operate actively in quantifying any inaccuracies. This may affect the level of any penalties that may be due, and will normally also reduce the amount of time and effort that you need to spend on the enquiry.

Where the initial information you requested gives you reason to believe that the return may be inaccurate, you should try to arrange a meeting with the taxpayer or write to them at the earliest opportunity to discuss your concerns. Explaining your concerns in as much detail as possible gives the taxpayer the opportunity to make a full disclosure and may avoid an application to the tribunal for a closure notice EM1975+.

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How you approach the question of inviting the taxpayer to disclose any inaccuracies will depend on the circumstances of the particular case.

Where you suspect there may be an Avoidance Scheme in place, liaise with the appropriate Avoidance team.

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