At a time when many individuals’ and companies’ priorities are elsewhere and a significant number of HMRC’s technical resources are being used to administer and deal with COVID-19 related support packages, it is perhaps unsurprising that our Tax Investigations team have seen a number of instances of HMRC offering taxpayers the option to put a temporary hold on ongoing enquiries and effectively allowing a “break” from proceedings. It is possible to request this work is continued, which may be the case particularly where the enquiry is in the process of being concluded, however, generally speaking from recent discussions with our private clients, the majority have asked for us to request the enquiry continues rather than letting the situation go stale. Corporate clients in certain sectors may however feel differently and want the matter paused.
HMRC has also confirmed that, despite COVID-19, it will continue to enforce the 30-day deadline for reporting mentioned in offshore assets “nudge” letters sent to taxpayers in February 2020. They have said however that "those who need more time to gather information should let us know, and we will continue to take a reasonable and proportionate approach to such requests". These offshore “nudge” letters were sent by HMRC to taxpayers and stated that they were aware that the taxpayer had an overseas property and/or offshore assets, income or gains (based on information HMRC had received through the UK’s tax exchange of information agreements with other countries).
If you or one of your clients have an open enquiry or have received an offshore assets “nudge” letter and are not sure what to do, please feel free to contact us to discuss the best way forward.