Entertaining

My Ltd Company client has has an employer compliance visit. In the accounts there is staff entertaining, other entertaining and subsistence.

Subsistence and staff entertaining have been claimed in the company;'s tax comps.

Other entertaining has been added back.

No enries were made on forms P11d.

During the ECR the compliance officer has asked for evidence of the entertainment expenditure to confirm that it has a genuine business motive. By evidence I mean for each item (there are hundreds) she wants the following:

Date of expenditure
Amount spent
Venue

These can be ascertained from the receipts so no particular problem there. Also:

Name of persons entertained
Name of organisation represented
Position in organisation represented
Nature of business discussed

I would think that my client will tell me when we meet that they did not record this information.

In which case the compliance officer will assess for PAYE/NI.

However, as these costs were added back in the tax comp is there not an element of double taxation? Will the compliance officer take this into account? Or is it correct to amend the tax comps? Or will in fact the compliance officer say hard luck they didn't follow procedure?

Thanks.

Rob