Many advisers will be concerned that due to the current lock-down conditions, they do not know what is happening with their ongoing investigation cases. Markel Tax has complied a helpful summary for advisers and their clients.
HMRC activity
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In-line with Government announcements on 17 March, HMRC officers were instructed to not return to their offices if they could work from home.
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On Friday 3 April, HMRC officers were instructed to pull back from customer-facing compliance work, unless the customer wished to proceed with the enquiry.
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Letters giving the option to suspend enquiries are now being issued to clients, but also saying that where statutory time limits are in point they may have to write to them again.
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Some new compliance activity is continuing, but the early indications are that it is in cases where if it were not for the enquiry, a repayment would be made and HMRC want to ensure that the repayment is due. The appears to be the case for both VAT and direct taxes.
Advice for clients
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In situations where agents are in email correspondence with HMRC officers, the case officer should continue correspondence electronically and send copies of any statutory notices via email to the agent as well as by post to the client.
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The majority of HMRC officers should be able to correspond electronically with agents, providing the agent agrees to HMRC’s email protocol.
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In situations where their usual offices are in lock-down and they are unable to visit them, agents need to make clients aware that they do not have access to HMRC mail and so anything a client receives directly should, where possible, be passed on.
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If there is any concern around whether or not mail has been sent to a closed agent’s office, call HMRC and discuss provision by email or an alternative address.
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Where any deadlines have been missed as a result of the inability to access post, late appeals under the ‘reasonable excuse’ provisions should be made, but remember that under those provisions, failures should be rectified as soon as the excuse ceases to apply.
For further information, please contact Nathan Ross-Sercombe on 020 7953 6355 or nathan.ross-sercombe@markel.com.