What to consider prior to determining whether to use an intervention: making and issuing a Notice of Direction: applying the measure: the Notice of Direction (NoD): who receives the NoD and how?
Who receives the NoD?
It is essential that the NoD is addressed to the correct entity. For example, if the taxable person is a limited company it should be addressed to that limited company. If it is a partnership then all members of the partnership should be named.
Prior to issuing the NoD you should confirm that any named directors are still named directors. You should ensure that a record is kept of the list of directors at the time the enquiry is made.
How should the NoD be issued?
Preferably the NoD should be handed to the taxable person and a signature obtained to evidence receipt. This will also enable the taxable person to ask questions and for HMRC to clarify any issues.