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Power Failure?

Richard Clarke and Jennifer Knowlson of PricewaterhouseCoopers LLP's tax investigations network discuss the rights and powers of the taxpayer involved in an enquiry or other HMRC 'intervention'
Tax agents often find themselves involved in HMRC enquiries into their clients' tax affairs whether corporate or personal aspect or full from HMRC's local compliance network or one of its specialist offices. In most cases these enquiries follow a well-trodden path — information and documents are requested by HMRC correspondence is entered into issues are agreed or negotiated and the enquiry is closed (with or without adjustments).
Sometimes the enquiry deviates from this path perhaps because a stalemate is reached on a technical point; or the enquiry encompasses a number of complex inter-linked issues; or because there...

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