Commentary

A6.933 How HMRC carry out a review

Administration and compliance

A6.933 How HMRC carry out a review

A6.933 How HMRC carry out a review

There is no legislation governing the way in which a review should be carried out although HMRC do rely on their information and inspection powers1 as set out in A6.903.

Typically a review has six stages:

  1.  

    •     initial contact by HMRC

  2.  

    •     HMRC visit (but not in all cases)

  3.  

    •     conclusion of issues and agreement of liability (excluding penalties)

  4.  

    •     meeting to conclude negotiations and agree the level of penalty

  5.  

    •     formal agreement, and

  6.  

    •     payment

The whole process can take a considerable time; some cases take a number of years. The review is usually

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