HMRC Tax Inspection Notices
What to Expect

Evan Wright


An HMRC tax inspection will usually be initiated with a straightforward request to provide information and documents so that a tax payer's tax liability can be properly assessed. Where necessary, HMRC have the power to obtain authority from the first tier tribunal to request the information or to enter and search premises. Although this does not confer a power to use force, failure to co-operate can lead to financial penalties. Where forced entry is justified, HMRC can use other powers to enter (without notice) with a warrant permitting the use of force. Similar powers allow HMRC officers to enter and request information / material in Excise investigations.

This briefing note is a summary of what a corporate or individual tax payer can expect when faced with different notices and/or officers seeking to use a variety of powers in the course of obtaining information. It is not a substitute for specific legal advice in particular cases. Click on the links for articles on HMRC dawn raids, a 'Quick Guide' for businesses that become the subject of an unannounced HMRC search and guidance on Legal Professional Privilege.

The Notice of Inspection process should be distinguished from the Excise Visit Process. This note deals primarily with the former but it will assist clients to know that HMRC can use different powers to inspect and seize documents where the enquiry concerns excise goods. The references to excise powers in this note are confined to the information notices officers serve in the course of an excise visit. The note also includes references to the S161 CEMA powers of entry and search, together with powers to enter by warrant in accordance with The Police and Criminal Evidence Act.

Evan Wright

T. 0161 828 8315
M. 07850 207 306

  1. 1. Notice to produce documents [and / or] provide information

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  2. 2. Taxpayer Notice: Letter before applying for Tribunal approval

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  3. 3. Taxpayer Notice: Tribunal approved

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  4. 4. Confirmation of tax inspection and notice to produce documents and information

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  5. 5. Confirmation of business premises tax inspection and notice to produce documents* and information

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  6. 6. Inspection Notice: Authorised officer agreement

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  7. 7. Announced Inspection Notice: Tribunal approved

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  8. 8. Unannounced Inspection notice: Tribunal approved

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  9. 9. Documents / Information subject to Legal Professional Privilege

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  10. 10. HMRC Factsheet - Unannounced visits for inspections

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  11. 11. Excise Visit Information Factsheet

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  12. 12. S161 Customs and Excise Management Act 1979

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  13. 13. Other Powers of Search and Seizure

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  • How JMW Can Help

    If you, your business or one of your clients requires advice in relation to an HMRC notice, search, dawn raid, investigation or prosecution, please contact our regulatory team on or 24hr line - 0845 402 0001

    Services include :-

    • Telephone advice
    • Attendance at a raid or inspection
    • Representation during HMRC interviews
    • Advice from tax experts
    • Representation at tribunals
    • Representation at the lower and higher criminal courts 

    JMW is a full-service law firm and we offer associated guidance from nationally recognised leaders in areas such as corporate recovery, employment, media (and reputational management) as well as commercial litigation and debt recovery.

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