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HMRC Powers

Andrew Watt Managing Director Tax Disputes & Investigations Alvarez & Marsal Taxand UK LLP reviews HMRC's powers and practice in direct tax criminal investigations
One of the inevitable consequences of the merger of the Inland Revenue (IR) and HM Customs & Excise (C&E) in April 2005 was the need to review and align the powers and practices of fraud investigators in the respective Departments. The first major outcome of this overhaul was the abandoning of the 'Hansard' process under which the IR had investigated serious tax fraud for more than 60 years. This was replaced in September 2005 by the Civil Investigation of Fraud (CIF) procedure. Whereas 'Hansard' had always carried the inherent threat of criminal prosecution at any stage of the proceedings not only for false disclosure but also for...

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