Commentary

A6.603 Pre-return compliance checks

Administration and compliance

A6.603 Pre-return compliance checks

A6.603 Pre-return compliance checks

HMRC may examine contemporary records and discuss them with the people who completed those records before a return is filed1. HMRC may also carry out real-time checks into tax planning or avoidance schemes as they are being developed or implemented, rather than having to wait until a return has been made, although it must have evidence to support the need to carry out such a check, and the information or documents it asks for must be reasonably required for the purpose of checking a person's tax position. The use of formal powers to obtain information necessary to establish the tax position will only be needed where it has not been provided following an informal request.

A risk must be

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