Commentary

A6.410 Meetings with the taxpayer (or representative) during the course of an enquiry

Administration and compliance

A6.410 Meetings with the taxpayer (or representative) during the course of an enquiry

A6.410 Meetings with the taxpayer (or representative) during the course of an enquiry

HMRC takes the view that meetings play a vital part in the enquiry process as they help establish facts, settle any points of disagreement and reach an agreed settlement with the taxpayer. However meetings can be expensive, inconvenient and stressful for the taxpayer and HMRC recognises that not all enquiries require a meeting.1.

The taxpayer's accountant (if he has one) is normally invited to attend any meeting, but is not obliged to do so if either he or the taxpayer objects. This can be costly for the taxpayer and HMRC should not ask for a meeting unless it is necessary2. HMRC does not have the power to compel a taxpayer or accountant to attend a face to face meeting, although the officer will make all efforts to persuade the taxpayer (and his agent) to attend. Officers are given guidance on how to overcome objections3. Where an agent is present in a meeting with the taxpayer, the officer will insist that replies to factual enquiries are answered by the taxpayer himself, although the agent may be asked to deal with questions of a technical nature. The agent should not however be prevented from asking the taxpayer to clarify any answer they have given to HMRC4.

With regards to companies, HMRC may ask to meet with officers or employees of the company to explain matters of which only they have first hand knowledge. There is no obligation to

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