ECH22140 - Settlement: Recovery in Further Reviews

Where it is argued that payment of any liability being sought is precluded by a previous inspection the ECO should

HM Revenue & Customs ‘discovery’ powers are not necessarily limited by a previous review of an employer’s or contractor’s business records. Much will depend on the facts and circumstances of the previous review.

The ECO should consider what

  • records were examined
  • was discussed with the employer (particularly by reference to the notes of meeting)
  • instructions were given (by reference to correspondence and so on).

Additionally consider from the current review

  • how the irregularity has now come to light and
  • what this says about whether the previous ECO could have been expected to notice the irregularity.