1. John Baldwin HMRC Enquiries An Update

2. John Baldwin • Last 11 years with Revenue heading up Investigation team • Worked for CCH/IRPC Taxation Services for over 13 years • Promoted to Managing Consultant in 2002 • Manages team of 6 tax and VAT consultants 2

3. Risk Assessment • What selection criteria do the Revenue use? • What steps can you take to lessen the risk of being selected? • How are HMRC Inspectors judged on their results ? 3

4. Revenue Information powers • Inspectors still asking for private bank etc statements in opening letters. • Is Inspector entitled to see trader’s diaries/appointment books? • Offshore Bank Accounts • Tenants Deposits Schemes • Taylor v Bratherton SPC00448 4

5. Revenue Meetings • Why are the Revenue insisting on these in their opening letters? • Do we have to attend? • What preparation can we undertake? • Are we entitled to a detailed agenda? • What are our rights during a meeting? • What should we look out for ? • Meeting Notes. 5

6. Discovery Provisions • S29 TMA 1970 • 6 years or 20 years ? • Basis for PY additions – based on RPI • Scorer v Olin 6

7. Additions – Quantification & Extent • What methods might HMRC employ quantify additions to profits ? • How can these be countered ? • How many earlier years will be involved ? • How will these earlier additions be quantified ? 7

8. Appeals Units • Why set up ? • Who do they comprise ? • Improvement ? 8

9. New Penalty Regime • FA 2007 • Mistakes/Misinterpretations - no penalty • Failure to take care - range 15% - 30% • Deliberate - range 35% - 100% 9