A6.620 Inspection powers—general rules
With effect from 1 April 2009, HMRC has the power to enter business premises and inspect them, together with any business assets and business documents on those premises1, when this is reasonably required for the purposes of checking a person's tax position. Previously for direct tax purposes, officers could enter premises only by invitation. It may only inspect those business documents which can be required by an information notice2.
'Inspect' means to examine; this power does not give HMRC the right to force entry, or to search. HMRC's guidance to officers carrying out inspections is that3:
'You may look at what you can see but you may not look for something that you cannot see.'
HMRC has said that it will only carry out an inspection where it considers this to be the best and most effective way to tackle risk.
'Business premises' means any premises (or a part thereof) used in connection with the carrying on of a business4. The definition includes land and buildings, but also 'means of transport'5. A means of transport in this connection is one which might be used as business premises, for example a mobile fish and chip van or a market stall run from a van.
HMRC confirms that it will not be seeking to enter all the