HMRC Enquiries
Being scrutinised by HMRC is not fun for anyone. Our knowledgeable tax investigations specialists will represent you and safeguard your rights.
We know HMRC enquiries are stressful.
The enquiry regime is complex.
The financial risk of extra tax, interest and penalties to pay is worrying. The pressure is compounded by the extra time it takes to deal with HMRC.
We have the expertise to deal with HMRC on your behalf.
How we can help you
Tax is complicated.
Self-assessment enquiries are not immune from that complexity so it may be that technical or procedural errors have been made by HMRC which an experienced specialist can identify. These may appear small, but they can impact on the chosen strategy and the validity of the entire enquiry.
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Case studies: HMRC enquiries
Validity of enquiry
The client’s accountant provided data to HMRC without question; HMRC asserted that adjustments were needed and the client then sought a second opinion from Crowe. We rightly questioned the validity of the enquiry notice itself which led to the enquiry being closed without amendment to the tax return.
Closure notice
HMRC opened an enquiry into one family member, then sought to justify a deep exploration into the financial history of the family’s businesses. Crowe provided only data considered to be relevant, or ‘reasonably required’, and successfully applied to the tax tribunal for a closure notice. The tribunal noted that HMRC’s continued questions amounted to a fishing expedition.
The client’s accountant provided data to HMRC without question; HMRC asserted that adjustments were needed and the client then sought a second opinion from Crowe. We rightly questioned the validity of the enquiry notice itself which led to the enquiry being closed without amendment to the tax return.
HMRC opened an enquiry into one family member, then sought to justify a deep exploration into the financial history of the family’s businesses. Crowe provided only data considered to be relevant, or ‘reasonably required’, and successfully applied to the tax tribunal for a closure notice. The tribunal noted that HMRC’s continued questions amounted to a fishing expedition.
Company enquiries
HMRC opened an enquiry into the holding company of a group and asked numerous questions about entries in the consolidated accounts which of course include the results of all group companies which were not under enquiry after the deadline for opening additional enquiries had passed. We reminded HMRC of the relevant enquiry legislation and provided responses relating solely to the holding company’s financial statements, following which the enquiry was closed with only a few minor amendments.
Reasonably required
During an enquiry into a Limited Liability Partnership (LLP) HMRC asked to see the LLP Agreement. We argued that the particular LLP Agreement was not reasonably required to check the LLP return as it would not affect the LLP’s (or individual members’) profits but would include numerous non-financial clauses covering matters such as internal governance which are not only confidential but also have no bearing on the tax return under enquiry. HMRC reluctantly closed the enquiry without amendment.
HMRC opened an enquiry into the holding company of a group and asked numerous questions about entries in the consolidated accounts which of course include the results of all group companies which were not under enquiry after the deadline for opening additional enquiries had passed. We reminded HMRC of the relevant enquiry legislation and provided responses relating solely to the holding company’s financial statements, following which the enquiry was closed with only a few minor amendments.
During an enquiry into a Limited Liability Partnership (LLP) HMRC asked to see the LLP Agreement. We argued that the particular LLP Agreement was not reasonably required to check the LLP return as it would not affect the LLP’s (or individual members’) profits but would include numerous non-financial clauses covering matters such as internal governance which are not only confidential but also have no bearing on the tax return under enquiry. HMRC reluctantly closed the enquiry without amendment.
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