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HMRC cannot circumvent the restrictions on its access to audit working papers merely because the same firm submitted the company’s audited accounts to HMRC with the tax return which it prepared, reports Helen Adams (BDO).

Are some corporates being too complacent and where might their current efforts be deficient, asks Jason Collins and Penny Simmons (Pinsent Masons).

Four recent commentaries examine different aspects of the tax compliance landscape.

     

    Kate Ison (Bryan Cave Leighton Paisner) reviews the department’s strategy.

    Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.
     
    The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).
     
    HMRC needs to exercise more care when applying for search and seizure warrants, writes Patrick Cannon (15 Old Square Tax Chambers).
     
    Large companies should refresh their raids and critical incident procedures in the event that HMRC decides to investigate, writes Jason Collins (Pinsent Masons).
     

    Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.

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