(This archived guidance relates to HMRC discretionary
practice before the 6th April 2006. For current guidance on
Registered Pension Schemes see the Registered Pension Schemes
Manual)
Inland Revenue Special Compliance Office (Liverpool)
Bootle 7th floor the Triad Stanley Road Bootle Merseyside L69
9EJ
Tel: 051 944 7916 (check)
Your liaison inspectors are:
We would like to see any cases which might lead us to companies
or individuals involved in tax avoidance or evasion on a
potentially large scale. Our normal criterion is a minimum
potential tax loss of £100,000 but the scale of the tax loss
may not be evident from your file.
Shown below are pointers to the type of cases we are looking
for. The list is by no means exhaustive and we are prepared to
consider any case where the circumstances are unusual and detailed
investigations may uncover additional liabilities.
Formal submissions and preparatory work are not required.
Your liaison inspector will welcome telephone approaches and
can see you at the next liaison visit if necessary.
General Pointers
Any puzzling transactions ie with no apparent logic behind
them.
Suspicious transactions with connected persons.
Any activity which suggests trading by the pension fund (eg
extension of employer’s trading activity in to the scheme,
stock lending etc).
Pension Fund or investment manager suspected of fraud or
impropriety eg Maxwell.
Indications that the Inspector suspects avoidance or evasion
by the employer.
Pension Fund assets available for the use of directors,
employees or their families.
Purchase or sales at under or overvalue (say £500,000
under/over).
Activities of the Pension Fund similar to those of the
related Employer - might indicate trading.
Money invested or lent by the Fund becomes irrecoverable eg
the borrower goes into liquidation.
There seems to be a loophole which is being exploited.
Serious consideration is being given to non-approval or
withdrawal of approval.
The Pension Fund has a captive company.
Overseas Connections
Cases with Eire connections.
Links with tax havens eg. Channel Islands, Isle of Man,
Liechtenstein, Panama, Cayman Islands, Netherlands, Antilles.
Transactions with overseas companies, trusts and settlements.
Transfer of assets/trustees abroad.
