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HMRC internal manual

Enquiry Manual

Working the Enquiry: Meetings: General

Meetings play a vital part in full enquiries under SA and will often be appropriate in aspect enquiries of substance. The information you need for many enquiries will consist not just of records and documentation but also of explanations from the taxpayer. It will often save time and cost all round if you obtain those explanations at a meeting, rather than by correspondence, at an early stage in the enquiry.

On some occasions an early meeting with the business’s book-keeper or accountant will be valuable in understanding how the business records were built up and link together. Such meetings should lead to a better understanding of how the accounts have been prepared and may enable you to resolve some issues without troubling the taxpayer.

Your job at this stage is to seek the information you need to check the taxpayer’s return, or the particular aspect of it that you are looking into. Although you may have selected the return for enquiry because it appeared to present particular risks you should not imply that you think there are understatements until you have had an opportunity to consider all the facts.

The number of meetings, the subject matter and who attends will depend on the nature of the enquiry.

You should bear in mind, however, that meetings can be expensive and inconvenient for taxpayers. You should not seek meetings routinely when you do not need explanations from the taxpayer.

You must make notes of

  • any meetings you hold with the taxpayer or agent
  • any telephone conversations in which you discuss matters relevant to the enquiry.

Your notes should be a factual summary and should cover all the important points of a meeting or telephone conversation. You should normally provide a copy of your notes to the taxpayer or agent and invite them to agree that the content is accurate.

These notes are important evidence and it may be necessary to present them before a tribunal.