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					John Baldwin
HMRC Enquiries
An Update
 John Baldwin

 Last11 years with Revenue heading up
 Investigation team
 Worked for CCH/IRPC Taxation Services for over
 13 years
 Promoted   to Managing Consultant in 2002
 Manages   team of 6 tax and VAT consultants




                                                   2
Risk Assessment



 What   selection criteria do the Revenue use?
 What steps can you take to lessen the risk of being
 selected?
 How   are HMRC Inspectors judged on their results ?




                                                        3
Revenue Information powers

   Inspectors still asking for private bank etc statements in
    opening letters.
   Is Inspector entitled to see trader’s diaries/appointment
    books?
   Offshore Bank Accounts
   Tenants Deposits Schemes
   Taylor v Bratherton SPC00448




                                                                 4
Revenue Meetings

   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 ?
   Meeting Notes.




                                                                       5
Discovery Provisions

 S29   TMA 1970
6   years or 20 years ?
 Basis   for PY additions – based on RPI
 Scorer   v Olin




                                            6
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 ?




                                                       7
Appeals Units

 Why   set up ?


 Who   do they comprise ?


 Improvement      ?




                             8
New Penalty Regime

 FA   2007
 Mistakes/Misinterpretations   - no penalty
 Failure   to take care - range 15% - 30%
 Deliberate -    range 35% - 100%




                                               9

				
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