Are there any guidelines in the public domain that advise under which circumstances, on the closure of an enquiry, HMRC should ask for a certificate of full disclosure? At present I cannot detect a pattern.
Thanks
With kind regards
Clint Westwood
Replies (5)
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I thought it was routine for them to ask for one. They've always done so with cases I've handled
Yes it's routine for them to ask. There is no obligation on the taxpayer to complete it though.
I think it will depend on the grade of the HMRC officer conducting the enquiry, bearing in mind that even Tax Officers (one below HEO level) are doing S9A work these days. They will, typically, only deal with aspect enquiries and even then, relatively straight forward. It's unlikely that they would even consider a certificate of full disclosure.
The higher up the HMRC food chain you go, though, the more complex an enquiry may be, including expanding into a full enquiry from an aspect, and so more likely for a certificate to be requested.