HMRC compliance check visits

By Tolley in association with Lesley Fidler of Baker Tilly
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The following Corporation Tax guidance note by Tolley in association with Lesley Fidler of Baker Tilly provides comprehensive and up to date tax information covering:

  • HMRC compliance check visits
  • Initial contact from HMRC
  • Pre-visit disclosure
  • Before the visit
  • The initial meeting with HMRC
  • Following the meeting: the employer
  • Following the meeting: HMRC
  • Conflict with an earlier compliance check
  • The communication phase
  • A selection of typical irregularities

Initial contact from HMRC

The first contact from HMRC will normally be a letter, either:

  • highlighting specific areas and requesting information and records, or
  • requesting a time and date for a visit to review relevant records

The compliance check factsheet CC/FS3 ‘Compliance checks ― visits ― by agreement or advance notice’  will usually be enclosed.

A full list of compliance check factsheets may be found on HMRC’s website .

Contact by HMRC with the employer may be made by phone but arrangements must be confirmed in writing. The employer’s agent named on a form 64-8 on which the ‘Employer PAYE scheme’ box has been ticked will be sent a copy of the initial letter. Seven days’ notice of the inspection must be given unless a shorter time is agreed with the employer. Any doubt about the nature and extent of the records to be reviewed should be clarified as soon as possible. Normally, records for up to 12 months will be requested.

If the suggested dates are not convenient then an alternative should be agreed as soon as is practicable. It should not usually be a problem arranging for the records to be reviewed away from the business, perhaps at the agent’s office.

Pre-visit disclosure

If it is known that there are irregularities in current or previous years then consideration should be given to disclosing these at the earliest opportunity. It is very difficult to envisage a situation in which withholding this information from HMRC could ever be a justifiable course of action. Once notification of the visit has been given, the disclosure will no longer be regarded as unprompted unless the disclosure is entirely unrelated to employer compliance. Nevertheless, telling HMRC of such irregularities is

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