Lee Sharpe warns that HMRC is amassing several sanction powers which are more troubling than some may realise.
Traditionally, enquiry amendments and tax penalties are treated as civil cases; in other words, not only is HMRC supposed to remain polite, but the legislation focuses primarily on a financial reckoning (assessment) and punishment (penalty).
Put another way, HMRC is mostly about the money: tax, interest and penalties.
Weapons in HMRC’s armoury
Broadly, the closest that even the naughtiest taxpayers will have come to a criminal sanction is to risk a ‘COP 9’ investigation, where HMRC formally tells the individual taxpayer, under Code of Practice 9 (aka its contractual disclosure facility), that they are suspected of serious tax fraud, but HMRC will nevertheless offer immunity from
