HMRC production orders: what are they and how should you respond? by Adam Craggs and Michelle Sloane

Adam Craggs and Michelle Sloane explore HMRC’s powers to compel the production of documents or information during a criminal investigation.


The ability of HMRC to compulsorily obtain information in the course of a criminal investigation is an important power available to HMRC.


When are these powers used?


Notices to compulsorily produce documents and information are commonly used by HMRC investigators during the course of a criminal investigation to compel the disclosure and production of information held by professionals in relation to their clients, which could not be voluntarily produced to HMRC due to client confidentiality obligations owed by the adviser to their client. These compulsory powers are commonly used to obtain documents and information from banks, accountants, company secretaries/company services providers and tax advisors.

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