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Handling Avoidance Enquiries

James Bullock and Jason Collins McGrigors LLP review the tactics and procedures involved in HMRC enquiries in avoidance cases
As horseracing fans will be aware the Cheltenham Gold Cup and the Grand National are almost upon us bringing the 'steeplechase' season to a close for another year. Conversely HMRC's crackdown on anti-avoidance is well under way with no sign of the finishing line in sight. Special Civil Investigations (SCI) now focuses principally on countering anti-avoidance and particularly targeting marketed avoidance schemes.
The civil investigation of fraud (CIF) procedures under Code of Practice 9 (formerly Hansard matters) have been largely transferred to regional CIF teams and criminal investigations have been transferred to an entirely separate unit. In practice this means that HMRC's specialist forensic investigation resources...

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