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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
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Examining Accounts: Records Examination - Planning: Where to Seek a Meeting

Records examination in the office

For many enquiries it will be sensible to obtain most of the documentary evidence that you need before seeing the taxpayer. This could include not just the underlying records but also any written explanations that it should be relatively easy for the taxpayer or agent to provide for example, the nature of the work done to arrive at the figures included in the returns.

It will be sensible to adopt this approach where the nature of the records and the information you need is fairly clear and where you are proposing that the records should be delivered to your office for examination there. In those cases, examining the records before seeing the taxpayer is likely to save time at the meeting and in some cases may even avoid the need for a meeting at all. It will also have the advantage that you will be able to give the taxpayer or agent a clearer idea of what it is that you want to discuss at any meeting.

This approach of seeking documentary information first should not be allowed to develop into a protracted correspondence which simply delays a necessary meeting with the taxpayer. You should aim to get the documentary information in as quickly as possible EM2800+ and then follow this up quickly with any meeting needed for further discussion. If you have difficulty in obtaining the information promptly it may be sensible to ask for an early meeting with the taxpayer in order to explore the difficulties and seek the taxpayer’s co-operation, even though you may not yet have received all the documentary information that you would ideally like.

Examination of records at taxpayer’s premises

In other cases it may be appropriate to examine the records you wish to see (for example business records) at the taxpayer’s premises. In that case discussion with the taxpayer and agent may well take place during and as part of the records examination. This will give you the opportunity to explain the scope and nature of your enquiries and seek any necessary clarification of the records and record keeping methods. In some cases you will not want, at this stage, to put any conclusions or concerns arising from your examination to the taxpayer until you have had time to do more work. But in other cases - particularly smaller cases involving simple records - you may be in a position to put your conclusions to the taxpayer, and even agree them, at this initial meeting. In such cases the opening of the enquiry will in effect merge into the working and even the conclusion of the enquiry. It is not possible to lay down hard and fast rules about when this should happen because it will inevitably depend on the nature of the records and the conclusions you draw from your examination of them.