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Full proof: more needed from HMRC to discharge their burden of proof

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HMRC have extensive powers to assist them in the collection and management of revenue, including the ability to issue information notices, discovery assessments and penalties. However, HMRC must meet relevant conditions before exercising these powers and they also have the burden of showing they have met these conditions. Recent cases have warned that HMRC must take this burden seriously and it is important that taxpayers are aware of the issues that have arisen.

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