It’s one to watch – at a time when HMRC is promoting the benefits of collaborative working BRC has the potential to impose unreasonable burdens and unjustifiable penalties on small businesses and to damage irreparably the relationship between HMRC and taxpayers and their advisers. With BRC HMRC finds itself at a crossroads: let’s hope it goes in the right direction.
In-year record-keeping penalties – TMA 1970 s 12B: HMRC now believes it can charge penalties in-year if records are not in HMRC’s view ‘adequate’ when they come to call. The statutory test is whether the records kept enable a taxpayer to make a correct and complete return so it is hard to see any legitimate basis for charging a penalty until it is demonstrated that the return is...