Prior to the merger of the Inland Revenue and HM Customs and Excise in April 2005 to create the new department HM Revenue & Customs (HMRC), information was regularly exchanged between ‘authorised officers’ of Revenue and Customs:-

‘for the purpose of assisting them in the performance of their duties’. (FA 1972, s. 127)

Where evidence which suggested evasion of VAT was discovered during an employer compliance review, it was generally passed on to Customs through the appropriate channels.

After its creation, HMRC issued a notice explaining how the powers of the two merged departments will be used. This confirmed that the powers previously exercised by one department will be used only to enquire into the taxes previously administered by that department. It was made clear, however, that there was no bar to passing on information discovered by any officer to assist another officer enquiring into another tax.

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