Published: 04 April, 2024
This Digest covers important topics relevant to professionals specializing in managing tax investigations as well as those whose clients come under HMRC scrutiny. The information held by HMRC and their improvement to coordinating targeted enquiries means virtually all approaches from HMRC will be because there are irregularities. Furthermore, the approach taken by Fraud Investigation Services is likely to require professionals specializing in investigations to manage or assist practitioners manage HMRC enquiries and disclosures. This is based on the underlying risk that HMRC will target taxpayers who make omissions or misrepresentations in disclosures, which is a separate prosecutable offence. Where professionals have assisted with disclosures and knowingly assisted with or advised on misrepresentations, they are likely also to be at risk. HMRC’s approach is becoming more focused and is starting to take a more assertive approach. An insightful interview between Anton and senior officials at HMRC reveals what may be expected in the next year or so. The Digest also provides a useful technical update and areas for practitioners to be aware of to better manage their and their clients tax risks.