CH23560 - Information & Inspection Powers: Information Notices: Taxpayer Notice: Meaning of 'reason to suspect'

鈥楻eason to suspect鈥� means that there are facts which, either alone or taken together with others, lead you to think that the person

  • may have been under-assessed to or may have underpaid tax or
  • may have claimed or been given excessive tax relief.

These facts will need to be disclosed

  • in resolving any appeal made against the notice, see CH24300 or
  • to the tribunal if the tribunal鈥檚 approval of the notice is sought, see CH24000.

Having a reason to suspect that tax may have been under-assessed, and so on, does not mean that you already have to be in a position to make an assessment. You will use the information power to enable you to decide what, if any, assessment must be made.

On the other hand 鈥榬eason to suspect鈥� does not allow you to make speculative enquiries, seeking information merely in the hope that something relevant will crop up. You must be able to identify specific risks.

FA08/SCH36/PARA21 (6)