Consultation outcome

The Tax Administration Framework review: New ways to tackle non-compliance – summary of responses

Updated 28 April 2025

1. Introduction

The consultation, The Tax Administration Framework Review: New ways to tackle non-compliance, was published on 30 October 2024. This document provides a summary of the responses received and the government’s next steps.

The consultation was open until 22 January 2025 and explored HM Revenue and Customs’ (HMRC) approach to correcting taxpayer inaccuracies in a claim or return. The opportunities explored have the potential to modernise and reform HMRC’s response to increasing numbers of similar, relatively small mistakes, including those seen when claiming credits and reliefs. The 4 reform opportunities covered were:

• amendments to conditions for making claims
• reform of Revenue Correction Notices (RCN)
• introduction of a partial enquiry
• a new power requiring taxpayers to self-correct

The government is grateful to those who contributed their views, evidence, and time to respond to this consultation. In total, 31 written responses were received, primarily from professional and representative bodies, tax agents, charities, businesses, and legal firms. HMRC also held a series of roundtable engagement events between December 2024 and January 2025 to discuss the content of the consultation with interested stakeholders.

In addition to responding to the questions on each reform opportunity, respondents provided comment on other aspects of the tax administration framework and HMRC in general.

Respondents showed their support for simplification and modernisation of the tax administration framework. There was strong encouragement for HMRC to prioritise fundamental reform of enquiry and assessment powers and harmonisation of powers across tax regimes. Although respondents saw the merit in some of the proposals, many said that HMRC should harmonise the powers first, form a view on what the new processes should be across all the taxes and only then consider whether any new powers are needed.

A number of respondents highlighted that the tax administration framework is complicated. Some stated that consolidation of existing tax management and administration provisions into one place, perhaps through a new Taxes Management Act, could help taxpayers and agents to navigate legislation more easily.

The majority of respondents emphasised the need for robust internal processes, operational guidance and educational materials, as well as appropriately trained staff and resourced teams. Respondents welcomed the government’s commitment to increase investment and fund 5,000 additional compliance officers and encouraged HMRC to invest in long-term, full and comprehensive training.

Some respondents showed continued support for HMRC’s mission of building a trusted, modern tax system. However, there were concerns that a lack of progress had been made, with some recommending an updated full review of HMRC’s existing powers, deterrents and safeguards, along with implementation of a roadmap for tackling both legislative and administrative tax complexity and the establishment of a Tax Simplification External Forum.

An overarching theme throughout the consultation responses was that any reforms would need to be carefully scoped and the technical detail subject to further consultation.

The following chapter provides a summary of the responses to the consultation and next steps.

2. Responses

Amendment to conditions for making claims

This section relates to questions 1 to 3 in the consultation document (see annex B) which explored whether additional checks and more upfront information could help HMRC make better judgements when claims are made.

The government asked stakeholders to consider:

• the introduction of additional information requirements to other claims for tax reliefs and allowances
• whether there are cases where this approach would be particularly helpful for customers
• how any additional administrative costs could be kept to a minimum

Of the 31 written responses received, 28 stakeholders commented on this proposal, with 21 responding to all 3 questions posed. Whilst some respondents saw the positives to the proposal, overall views were mixed.

Process, guidance and education

Matters around process, clear detailed guidance and education featured prominently, with many respondents noting that to mitigate the risk of costly administrative burdens, the policy would need to be carefully designed. Some respondents commented that agents, as opposed to non-represented taxpayers, may find it easier to supply upfront information as they are more likely to have access to the information at the time of submission. Observations regarding the process were also made, including that if upfront information requirements would speed up processing and support avoiding requests for information months later, there could be some merit in the proposal. There were also some comments relating to high volume repayment agents (HVRA). These included, only introducing the requirement to provide evidence under certain circumstances, such as for all new HVRAs or where there had been previous non-compliant behaviour and limiting involvement of certain areas of tax to only those agents who are regulated.

Timescales

Some respondents stated the need for realistic and proportionate claim processing timescales, with adequate HMRC resources needing to be in place to meet those. It was commented that any review by HMRC of information provided, must be concluded within the enquiry window. Respondents also noted that providing supporting information up front could minimise the likelihood of an enquiry being raised, which are sometimes seen as unduly lengthy. 

Technology

Greater use of digital technology was a common theme amongst respondents. Several respondents stated that HMRC need to ensure secure digital platforms are in place for both digitally capable taxpayers and agents to utilise, along with sufficient provisions for the digitally excluded. Some respondents suggested artificial intelligence driven technology and smart data capture could be utilised to review information provided. It was noted that any system needed to be consistently available across HMRC.

Administrative burdens

Comment around administration burdens featured prominently amongst many respondents. Some respondents noted that if the provision of evidence upfront provided taxpayers with certainty that their claim, once processed, was fully accepted as valid, they might be willing to accept the accompanying administrative burden and possible delay in receiving the repayment. However other respondents commented that increased requirements could deter taxpayers from claiming reliefs they are entitled to due to perceived complexity, cost and the hurdles involved.

Proportionality and usage

Proportionality of requirements featured considerably in responses, with a lot of respondents commenting that the additional time and cost burdens should not outweigh the benefits to the taxpayer and HMRC. It was stated that the information or evidence should be necessary and proportionate to the claim amount, with the ease of providing the information taken into consideration. There was some suggestion that HMRC could target the additional information requirement to specific areas, reliefs or claims. For instance, to high-risk claims where the potential return to the Exchequer exceeds the costs incurred by the taxpayer. Several respondents commented that a one-size fits all approach may not work.

Capacity and capability

HMRC capability and capacity featured amongst many respondents with a common theme being that HMRC must ensure it has sufficient resource and expertise to review the information provided. It was commented that if HMRC enquires into the claim and asks for the same information, taxpayers and agents will feel aggrieved. Many respondents commented that HMRC should make better use of the information it already has and that additional requirements should only be introduced where there is a gap and HMRC can commit to dealing with the information efficiently.

HMRC’s perceived current performance with similar information requirements, such as under the Research and Development additional information facility, was cited as a concern. Many respondents considered that the effectiveness of the Research and Development additional information facility should be evaluated before any new information requirement is implemented, and changes should be trialled with a small test group of taxpayers to establish their efficiency and to check that they do not deter claims. 

Reform of Revenue Correction Notice (RCN) conditions

This section relates to questions 4 to 8 in the consultation document (see annex B), which explored whether there were opportunities to reform revenue correction notices. The government asked stakeholders to consider:

• aligning the conditions for when HMRC can make revenue corrections, so that they are the same across relevant direct taxes
• aligning the ways revenue correction notices can be rejected
• the introduction of a mandatory requirement for taxpayers to provide evidence to support a rejection of revenue correction notice
• the introduction of a mandatory requirement for HMRC to explain why a correction was made
• any other ways the revenue correction notice process could be improved

Of the 31 written responses, 27 stakeholders commented on these proposals, with 19 commenting on all 5 questions posed. The majority of respondents were supportive of aligning revenue correction notices across the taxes and for a requirement for HMRC to explain why a correction was made. Views were more mixed on whether taxpayers should be required to provide evidence to support a rejection of a revenue correction notice. Some respondents thought HMRC should look to improve the compliance process first before reform of revenue corrections is considered.

Harmonisation

Many of the respondents recognised revenue correction notices as a valuable tool that enable HMRC to make simple corrections quickly and easily, without the need for an enquiry. The majority supported reforms that would harmonise the conditions for making revenue correction notices across direct taxes, as one process would be simpler to understand.

The majority of respondents supported aligning the methods of rejecting revenue corrections across the taxes, commenting that this might reduce errors and help taxpayers understand their rights and obligations. There was no clear consensus of how this alignment could be achieved but many respondents indicated they would welcome an extension of the time limits to reject income tax corrections, in line with Corporation Tax and Stamp Duty Land Tax. Many respondents suggested that digital routes should be incorporated into any reform in this area.

Many respondents raised concerns that revenue correction notices were not being used appropriately, commenting that it would be better to align the conditions so HMRC could only correct obvious errors, as is currently the case for Stamp Duty Land Tax. Some respondents felt that inappropriate use of revenue corrections undermines trust in HMRC.

HMRC explanations and taxpayer evidence

Almost all respondents supported the idea that there should be a requirement for HMRC to provide an explanation for a revenue correction. Respondents said that a clear explanation of why a correction has been issued is essential, promotes better understanding, co-operation, trust and would improve compliance. Some respondents went further and suggested HMRC should support their explanation by providing the data upon which it relies.

Many respondents considered providing clear explanations should already be standard practice and expressed concern that HMRC’s explanations in revenue correction notices are often vague and inadequate. Respondents said clear explanations would reduce the need for taxpayers to contact HMRC, reduce the number of rejections and ensure any remaining rejections were made on an informed basis.

Views on whether there should be a mandatory requirement for taxpayers to provide evidence to support a rejection of a revenue correction were more mixed. Many respondents commented that, while such a requirement could avoid unnecessary enquiries and speed up the compliance process, they were concerned it could be an additional burden on taxpayers and could lead HMRC to treat the revenue correction process as a mini enquiry.

Many respondents suggested that if taxpayers were required to provide evidence, then the time limit for them to reject income tax corrections must be extended beyond the current 30-day time limit. Respondents also suggested that HMRC would need to be clear in guidance and correspondence what evidence taxpayers would need to provide.

Though respondents were generally supportive of anything that helped improve openness and cooperation between HMRC and taxpayers, some questioned whether a mandatory requirement to provide additional information was necessary. Instead, respondents encouraged HMRC to seek such information on a voluntary and collaborative basis.

The majority of respondents who supported, in principle, the idea that evidence should be provided by taxpayers to support a rejection of a revenue correction said that there must be a corresponding requirement for HMRC to provide a clear explanation of why the correction was made.

Improving the process

Many respondents considered there were 2 key things to improving the revenue correction process. One was for HMRC to provide a clear and meaningful explanation of why a revenue correction was made. The other was for revenue corrections to only be used for obvious errors.

Many respondents said it would be helpful if HMRC were to clarify the circumstances when a revenue correction was appropriate and ensure revenue correction notices were not used for more complex issues.

Respondents also requested better guidance on dispute routes and the consequences to taxpayers of not taking action. Many respondents thought that improved digital services, in particular digital methods of rejection and providing required evidence, would improve the process.

Introduction of a partial enquiry

This section relates to questions 9 to 11 in the consultation document (see annex B) which explored introducing a partial enquiry power that would enable HMRC to enquire into a specific issue or section of a return.

The government asked stakeholders to consider:

• the effect of implementing a partial enquiry power
• the circumstances in which such a power might be deployed, and what would be appropriate safeguards
• what limitations should be attached to the use of this power and why

Of the 31 written responses received, 27 stakeholders commented on this proposal, with 18 responding to all 3 questions posed. The majority of respondents opposed the introduction of a partial enquiry power.

Concerns

Some respondents considered the case for partial enquiries had not been made, with many stating that it would add complexity within an already extensive tax statute. There were concerns that with the possibility of enquiries or compliance checks into other aspects of the return still being possible, this would increase uncertainty. Adequate safeguards and the prospect of endless limited scope enquiries (sometimes referred to as ‘aspect enquiries’) were raised as concerns. Some respondents took the view that the proposal seemed to be mainly about saving time and cost for HMRC. To ensure that compliance checks are undertaken efficiently and expediently, it was suggested that HMRC review its advice, guidance, and training to compliance officers.

Legislation

Many respondents considered that legislation already provides HMRC with the ability to enquire into any part of the tax return without the need for additional legislation. The consensus amongst respondents was that HMRC can already close individual matters down using partial closure notices and discovery powers, and that introducing a new type of enquiry would risk duplication, adding unnecessary complexity. It was noted that requiring taxpayers to self-correct or issuing a discovery assessment, would probably be more appropriate in most situations. There were a few respondents who considered a statutory basis for an enquiry into a specific issue could be useful, with benefits including access to fee protection insurance. Most, however, felt that HMRC could already achieve its aims through existing powers, with some respondents commenting that focus should be directed at improving its full enquiry process, enabling a full enquiry to deal with smaller issues swiftly.

Implementation

There were many comments around difficulties with implementation. Respondents felt an additional layer of intervention would complicate the compliance system further and lead to protracted, costly and administratively burdensome demands. Respondents considered that multiple partial enquiries into the same return could be confusing and potentially overwhelming for taxpayers and HMRC. It was suggested a partial enquiry would circumvent the important safeguard of HMRC only taking ‘one bite of the cherry’ when enquiring into a tax return. It was also considered that taxpayers and HMRC may take different views on which issues have already been dealt with, which could lead to increased disputes. 

Governance was noted as an area that needed careful consideration. The extent of HMRC’s ability to extend a partial enquiry into other areas of the return was noted as something that would need to be made clear. Respondents commented that safeguards would need to be substantially amended to ensure that any introduction of partial enquiries did not erode them and, at an absolute minimum, similar safeguards as those that exist with current enquiry powers would be required.

Possible use

Many respondents shared views on how a partial enquiry power could be utilised. It was suggested it should only be possible to have one partial enquiry opened into a specific return at a time, that a full enquiry should not be opened until any partial enquiry has been closed and that multiple enquiries into the same tax return should not be initiated where a full enquiry would be more efficient. Respondents also commented that partial enquiries should not be used to extend the normal statutory enquiry window, and that taxpayers should have the ability to make consequential claims following conclusion of a partial enquiry.

Timescales

A number of respondents supported obligations being placed on HMRC to work within specified time limits, with realistic response deadlines for both taxpayers and agents. There was, however, doubt that HMRC would be able to adhere to such obligations. It was considered essential that issues worked under a partial enquiry notice could be resolved quickly and that HMRC will need to allocate sufficient resources to ensure that this can be delivered. Some respondents felt that the ability of taxpayers to apply to the First-tier Tax Tribunal to direct HMRC to close a partial enquiry and the ability to appeal HMRC’s conclusions and computations, should be retained, whilst others considered there would be a substantially increased burden placed on the Tribunal service.

More generally, respondents commented that it would be better to pause this suggestion until the whole enquiry and assessment regime is reviewed and modernised as it may not then be needed. Some respondents expressed a desire to see a broader focus on more carefully reviewed and managed compliance checks to a set timeframe.

A requirement for taxpayers to self-correct

This section relates to questions 12 to 20 in the consultation document (see annex B). This chapter in the consultation explored a new power which would require taxpayers to self-correct their return, if required when notified by HMRC.

The government asked stakeholders to consider:

• how this power could be used and applied most and least effectively
• the merits, challenges, risks and benefits of requiring taxpayers to respond to a new notice and correct their own return
• obligations and reasonable timeframes for taxpayers and HMRC
• potential impacts, costs or burdens of introducing such an approach
• appropriate consequences for non-compliance and incentives for compliance; and
• appropriate and proportionate taxpayer safeguards

Of the 31 written responses received, 25 stakeholders commented on this proposal, with 18 responding to all questions in this section. Overall, respondents had mixed views on the introduction of the power as it was described in the consultation. Respondents could see the benefits to the principles explored in the consultation, such as enabling taxpayers to correct simple mistakes easily, and having appropriate timescales to act or respond. There were, however, concerns that the power as described was too specific and may not achieve the intended benefits.

Use of a new power

Several stakeholders felt this approach to tackling non-compliance could be applied most effectively where HMRC did not have enough information to make a correction itself or where the error was less complex. Several respondents said this power would be least effective where there was technical complexity or there was a need for a two-way dialogue, where an enquiry would be more appropriate.

Of those with mixed views, there was a strong consensus that the scope of the power was too narrow. It was suggested that a broader, more generalised requirement to correct would be the preferred approach. Several respondents stated that it could be better to have a general statutory requirement to correct within a specific period of time when the taxpayer becomes aware of any mistake in the entirety of their tax affairs, not just after HMRC prompted them. Respondents noted that this would align with the professional conduct in relation to taxation which requires agents to support clients with a full disclosure as opposed to a partial one.

Some respondents urged HMRC to consider its existing powers, and how better to utilise them, ahead of introducing any new requirements.

Merits, challenges, risks and benefits

Many of the respondents who were in favour of this type of approach said they could see the merits of requiring taxpayers to respond to a new notice and that correcting their own return would be a quicker, more efficient and less intrusive alternative to the full enquiry for certain types of error. Some also stated that a statutory underpinning could remove the uncertainty inherent in the current informal approaches. They asked that consideration be given to whether this approach would be covered by fee protection insurance policies.

Many respondents were concerned that if HMRC held any inaccurate information, they would send notices to taxpayers that shouldn’t receive them, noting that this could lead to a loss of trust between taxpayers and HMRC. Several respondents highlighted the need for HMRC to be adequately resourced in order to manage and follow up on responses to the notice.

Some respondents felt that a new power could add a layer of complexity, and that careful consideration would need to be given to how any new requirements interact with existing powers.

Obligations and reasonable timeframes for taxpayers and HMRC

There was consensus among respondents that the time limit for taxpayers to respond to notices, ordinarily 30 days, is too short. Most respondents suggested 60 or 90 days would be a more appropriate time scale, but that HMRC could retain discretion and the ability to lengthen this if required. Most respondents with views on timescales emphasised that HMRC should lead by example, and any timescales should equally apply to HMRC acting on or responding to information provided in response to a notice.

A number of respondents proposed timeframes should be harmonised across all notices, and that HMRC should not be able to issue a notice if the time limits for opening an enquiry, or assessment time limits had passed. Others also noted that to maintain fairness, taxpayers must be able to make consequential claims if their tax position changes after making an amendment.

Several common themes relating to obligations emerged across all responses. These included the need for simple and easily understood notices, robust guidance, and harmonised processes across as many taxes as possible. Most respondents cautioned that inadequate explanations would cause unnecessary worry, and that notices should be transparent, providing as much detail as possible to enable a taxpayer to make an informed decision or, if required, seek advice. Many respondents showed support for HMRC increasing the use of digital channels but noted the need to have an alternative method for those taxpayers who are digitally excluded.

Impacts, costs and burdens

Many respondents commented on the potential impacts, costs and burdens of introducing a new requirement to correct. A particular concern was that if the notice was for one issue for one year only, then correcting multiple mistakes spanning several years, will be less efficient and more time consuming for taxpayers, agents and HMRC. Several respondents felt this approach would increase costs for the compliant and their agents, and, with the ability to escalate into a full enquiry, could delay certainty for taxpayers. Several respondents suggested that a general statutory requirement to correct within a specific period of time when the taxpayer becomes aware of any mistake in the entirety of their tax affairs, could me more appropriate.

The need for careful targeting of notices was emphasised, along with the need for HMRC to improve its data analysis capabilities. Some respondents suggested a threshold test be introduced to restrict the circumstances where HMRC could issue a notice, to ensure that HMRC correctly identified taxpayers and targeted letters. For example, allowing an HMRC officer to issue a requirement to self-correct where they ‘reasonably believe that a return is incorrect in the light of information available to the officer’, broadly in line with the existing language found in the revenue correction notice provisions for ITSA and CTSA. Other respondents commented that, if appropriately targeted, the benefits of statutory correction notices could outweigh the impacts, costs or burdens which they created.

Consequences for non-compliance and incentives for compliance

Many respondents had views on appropriate consequences for non-compliance with a notice. Several highlighted that provisions such as higher rates for penalties for prompted disclosures already exist, and that consideration would need to be given to how such a requirement fits into existing penalty regimes. It was noted that new penalties would complicate matters.

Some respondents said that where there is ambiguity or discontent with a response, or lack of response, HMRC should open an enquiry into the relevant return or investigate the matter using its information gathering and assessment powers. Having certainty that an enquiry will follow if no response is received could provide taxpayers with a clear incentive to engage early. Almost all respondents asked that appropriate channels of communication be used, such as a secure online form or digital route with an alternative for those who are digitally excluded. It was strongly requested that HMRC should educate taxpayers via guidance and clear explanations of requirements. The majority of respondents highlighted that it would be unacceptable to impose penalties on taxpayers where no correction or amendment to any return is needed.

When asked to consider what incentives HMRC could provide to encourage compliance with a notice, respondents suggested the ability to receive lower or reduced penalties which may ordinarily apply for inaccuracies, and assurance of no further checks into the specific risk. One respondent highlighted the local authorities’ scheme of paying a reduced fine within 30 days as highly effective and that HMRC could offer something similar to taxpayers. Several respondents acknowledged that any framework introducing these rules must guard against the risk the incentivisation means taxpayers feel compelled to accept HMRC’s position regardless of whether it is correct. Respondents felt strongly that clear guidance and better access to support through various channels would be vital for an effective regime.

Safeguards

The majority of the respondents highlighted the importance of appropriate safeguards and included examples such as suitable routes for statutory appeal or other means of dispute resolution, reasonable excuse provisions, and both digital and non-digital alternatives. A number of respondents emphasised the importance of certainty and that honest taxpayers have a fundamental right to closure within a reasonable timeframe. Some respondents noted that if HMRC disagreed with the taxpayer’s response to the correction notice it should use its existing enquiry and assessment powers where already established powers and safeguards would apply.

Implementation

Several respondents highlighted the importance of adequately trained HMRC staff and better use of resources. Some believed that many of the issues raised in the consultation could be alleviated through better use of existing powers such as revenue correction notices and nudge letters. Of those respondents who were broadly supportive of continued exploration, several were keen to see further analysis, testing and welcomed the opportunity for further engagement on the detail of any proposals. Respondents highlighted the need for a clear vision of how any new power would interact with future focused HMRC programmes such as Making Tax Digital and digital transformations.

3. Government response

The government welcomes views on these proposed reforms to HMRC’s enquiry and assessment powers, which are intended to make it easier and quicker for taxpayers to put things right, while helping HMRC collect the right tax more effectively and efficiently. As part of delivering a modern and reformed tax administration system, the government is committed to continuing to review those aspects of the tax administration framework that relate to compliance. The perspectives provided by respondents are vital to informing robust policy development, and the government is committed to working closely with taxpayers, intermediaries and their representatives as policy reforms are designed and delivered.

The government acknowledges respondents’ desire for HMRC to prioritise its programme of wider reform of its enquiry and assessment powers. The government continues to consider that there would be benefits for taxpayers, agents and HMRC, to a broader coherent review of HMRC’s enquiry and assessment powers and welcomes the encouragement to prioritise this work.

The government considers the right approach is to continue the programme of greater fundamental reform. The government agrees with those respondents who noted that fundamental reform has the potential to save taxpayers and agents time and money, increase efficiencies for HMRC and reduce complexity for HMRC, taxpayers and agents. HMRC will continue to engage with stakeholders and analyse options to make it easier and quicker for taxpayers to get things right, welcoming further input on wider reform opportunities to either create a single set of powers across tax regimes, or more closely align the key provisions of these powers.  

The government recognises respondents’ support for simple and easy ways to correct errors, along with the concerns on how this could most effectively be achieved.  The government considers there are benefits to the reform of HMRC’s correction powers and welcomes the suggestions on appropriate obligations, sanctions and safeguards.

Building on the feedback received, HMRC will progress reform of its revenue correction powers and explore the most efficient approaches to taxpayer self-correction. The government will test the principle of greater simplification and harmonisation of compliance powers through these initial reforms, looking in more detail at the benefits and risks.

Most respondents felt that amendments to the conditions for making claims could be an added burden. The government acknowledges respondents concerns and will not be prioritising wide scale reform to the conditions for making claims. Feedback will be shared within HMRC to inform any future work.

The government acknowledges views that the introduction of a partial enquiry power could lead to uncertainty for taxpayers. Taking account of respondent’s helpful feedback, the government considers that the introduction of a partial enquiry power should not be prioritised and has no current plans to explore this further.

4. Next Steps

Many respondents provided detailed and considered feedback on all 4 reform opportunities posed in the consultation document. The government is grateful to all respondents who contributed their time and expertise. HMRC will continue to draw on responses to inform any future reforms across these policy areas.

As set out above, the government has identified the following that HMRC will take forward for further consideration: 

1. reform of revenue correction powers
2. approaches to taxpayer self correction
3. longer term work to develop and test policy options to harmonise and simplify compliance powers across tax regimes

The government is mindful that fundamental reform could take some time and believes there are ways to help address the challenges HMRC faces in tackling compliance for high volume low value risks more immediately.  This includes through reform of its revenue correction powers and exploring the most efficient approaches to taxpayer self-correction. Progressing these reforms will help address current operational challenges, while also offering benefits to taxpayers through easier routes of correcting errors and mistakes. Development of these initial reforms will enable the testing of the principle of greater simplification and harmonisation of compliance powers as part of the wider, longer-term work.

The government is committed to working closely with taxpayers and agents to ensure they are consulted as policy reforms are designed and delivered.

Annex A: List of stakeholders consulted

The government is grateful to the 2 individuals and following organisations who responded to this call for evidence:

• Association of Certified Chartered Accountants
• Association of Taxation Technicians
• Avalon Tax
• AW Tax Service Ltd
• BDO LLP
• Confederation of British Industry
• Chartered Accountants Ireland
• Chartered Institute of Taxation
• Contentious Tax Group
• Deloitte UK LLP
• DWF Law LLP
• Ernst & Young LLP
• Federation of Small Businesses
• Institute of Chartered Accountants in England and Wales
• Institute of Chartered Accountants of Scotland
• KPMG LLP
• Low Income Tax Reform Group
• Moore Kingston Smith LLP
• National Grid plc
• PKF Francis Clark
• Professional Passport
• PwC LLP
• RD Reliance Ltd
• RSM UK Tax and Accounting Ltd
• Slaughter and May
• TaxAid and Tax Help for Older People
• Tax Justice UK
• TaxWatch
• Vialto Partners

Annex B: List of questions

Question 1: What are your views on introducing additional information requirements to other claims for tax reliefs and allowances?

Question 2: Are there cases where this approach would be particularly helpful for customers?

Question 3: How could any additional administrative costs be kept to a minimum?

Question 4: What are your views on aligning the conditions for when HMRC can make corrections, so that they are the same across relevant regimes?

Question 5: What are your views on aligning the ways that revenue correction notices can be rejected, so that they are the same across relevant regimes?

Question 6: What are your views on introducing a mandatory requirement for taxpayers to provide evidence to support a rejection of a revenue correction notice?

Question 7: Do you think this requirement should extend to HMRC explaining why a correction was made and what evidence is required?

Question 8: What other ways could the revenue correction process be improved?

Question 9: What are your views on introducing a partial enquiry power to allow an enquiry into a specific issue?

Question 10: In which circumstances do you think such a power might be deployed and what would you see as appropriate taxpayer safeguards?

Question 11: What limitations do you think should be attached to the use of this power and why?

Question 12: What are your views on how this power could be used? Where do you think this power could be applied most and least effectively?

Question 13: What are your views on the merits and challenges of requiring taxpayers to respond to the new notice and correct their own return?

Question 14: What are your views on reasonable timeframes for a taxpayer to respond to a taxpayer correction notice and, subsequently, for HMRC to confirm its position?

Question 15: In addition to the above, what else might HMRC need to take into consideration when designing obligations?

Question 16: What are your views on any potential impacts, costs or burdens of introducing this approach?

Question 17: What do you think would be an appropriate consequence for non-compliance with a notice, and what factors should HMRC take into consideration?

Question 18: What incentives could HMRC provide to encourage the taxpayer to comply with a notice in the specified timeframe?

Question 19: What are your views on the potential benefits and risks to this approach: for taxpayers, agents and HMRC?

Question 20: What do you believe would be appropriate and proportionate taxpayer safeguards?