Last11 years with Revenue heading up
Worked for CCH/IRPC Taxation Services for over
Promoted to Managing Consultant in 2002
Manages team of 6 tax and VAT consultants
What selection criteria do the Revenue use?
What steps can you take to lessen the risk of being
How are HMRC Inspectors judged on their results ?
Revenue Information powers
Inspectors still asking for private bank etc statements in
Is Inspector entitled to see trader’s diaries/appointment
Offshore Bank Accounts
Tenants Deposits Schemes
Taylor v Bratherton SPC00448
Why are the Revenue insisting on these in their opening letters?
Do we have to attend?
What preparation can we undertake?
Are we entitled to a detailed agenda?
What are our rights during a meeting?
What should we look out for ?
S29 TMA 1970
6 years or 20 years ?
Basis for PY additions – based on RPI
Scorer v Olin
Additions – Quantification & Extent
What methods might HMRC employ quantify additions
to profits ?
How can these be countered ?
How many earlier years will be involved ?
How will these earlier additions be quantified ?
Why set up ?
Who do they comprise ?
New Penalty Regime
Mistakes/Misinterpretations - no penalty
Failure to take care - range 15% - 30%
Deliberate - range 35% - 100%