The main purpose of the initial enquiry or approach to the taxpayers is to
You should frame your questions carefully so that the taxpayers
are clear about precisely what information you need and all
information is requested at the outset. You should phrase your
questions in such a way that they can, if necessary, be lifted to
form the basis of a IHTA84/S219A information notice (
IHTM32201) should any delays arise in
replying to your enquiries. Any request for information should be
reasonable bearing in mind the degree of tax at risk.
If you have identified that significant tax is at risk or the case is to be treated as a full enquiry ( IHTM29022) there are further questions ( IHTM09053) that you should consider asking to
In some cases you may find it helpful to have preliminary discussions with the taxpayers to explain your concerns and requirements. This may allow you to agree jointly on the best way to take the enquiry forward.