Tax Enquiries, Closure Notices & Discovery Assessments - Live at Your Desk
HMRC is subject to strict limits on how and when they open tax enquiries and how tax assessments can be raised following the end of an enquiry period.
This 6 hour live broadcast session examines the framework and the limits placed on how assessments can be used against taxpayers.
The session is relevant to all accountants, tax practitioners and others involved in tax enquiries.
What You Will Learn
This live and interactive session will cover the following matters in the context of income tax, CGT, corporation tax, SDLT, IHT & VAT:
- HMRC enquiry powers/requirements for a valid enquiry
- How to conduct an enquiry/common pitfalls
- Disclosure of documents during an enquiry
- HMRC information powers during an enquiry
- How to obtain a Closure Notice
- Scope of taxpayer right to apply for a closure notice
- Jurisdiction and powers of FTT
- Making the application
- Time limits applicable to assessments
- Innocent, error, careless error, deliberate error
- Discovery assessments
- Burden of proof
- What is discovery?
- Taxpayer safeguards/HMRC gateway requirements
- Hypothetical officer; nature of test
- Review of case law, including Charlton (UT), Sanderson (CA)
- Revenue determinations, scope and limits
- Handling an enquiry
- Strategic review
- Review of facts/documents
- Preparation of chronology
- Preparation of issues matrix
- Review of law/statute/case law
Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.