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Published on 8 May 2024

The Tax Administration Framework Review: enquiry and assessment powers, penalties, safeguards - LITRG response


LITRG has responded to the latest call for evidence under the Tax Administration Framework Review, on enquiry and assessment powers, penalties and safeguards. 

a notebook with the word 'RESPONSE' typed on it, a magnifying glass, a pen and a pair of glasses
Drozd Irina /

This broad call for evidence discusses 22 reform opportunities across the three areas. In each area, we agree with the principles identified in the 2012 Powers Review, and with the broader objectives for the Tax Administration Framework Review.

On enquiry and assessment powers, we note there is a focus in the call for evidence on post-submission compliance. We encourage HMRC to be cognisant of the level and type of data that they receive and have in their possession pre-submission. We also note that there would be advantages for HMRC, the tax profession and some taxpayers if enquiry and assessment powers were consistent (or more consistent) across tax regimes.

On penalties, our comments are focused on how unrepresented taxpayers can find themselves in penalty situations which feel unjust – particularly where historic compliance is involved. We discuss opportunities to improve the suite of penalties which can apply to these taxpayers, with a view to minimising these inequities at the same time as simplifying the various regimes.

On safeguards, we set out the importance of ensuring that access to safeguards is optimised for taxpayers who are not represented by an agent. We highlight how a key element of improving access to safeguards is increasing taxpayer awareness and understanding.

Our response can be read here

LITRG’s response

Tom Henderson
Technical Officer

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