It is important to understand at the outset that the preparation of the report is a time-consuming affair. It is also expensive, because the specialist nature of the work means that little, if any, of it can be dealt with by junior staff. The client should be prepared for the expense and the intrusive nature of the enquiries which will be necessary. It will generally be found that this requires very careful handling if the relationship with the client is to be preserved. The client also needs to understand the scale and extent of the report and the importance of prompt delivery of information.


What must be avoided, out of fairness to the client, is the taking on by the adviser of a commitment to prepare a report which he knows is unlikely, for one reason or another, to be able to fulfil. For it is the client who will have to pay the price for delays or inadequacies in the report and the adviser should always consider whether his client might perhaps best be served if another firm were engaged with the capacity and experience to handle the task.


Assuming that the decision has been taken that the adviser will handle it itself, he must prepare himself for the undertaking and substantially adjust his workload to accommodate the additional work which the report will entail. A clear understanding of what is involved in preparing the report and the planning of a programme for obtaining the necessary information will help to achieve the satisfactory progress. It will also help with the handling and ordering of a great deal of information, much of which will itself open up new lines of enquiry.


HMRC normally allow six months for the production of the report. As it is unlikely, however that the scope of the report can be determined until at least some preliminary work has been carried out, this timescale can initially only be provisional. The adviser will not know in advance all the lines of enquiry he will have to pursue or how long these will take. Nor will he have any control over the length of time taken by third parties (e.g. banks and building societies) to provide him with information.


However, as soon as the adviser has an indication of a more accurate timescale, he should discuss this with HMRC at the earliest possible opportunity, and obtain their agreement to a revised programme. Late requests for an extension can unfortunately be regarded as delay by HMRC, with a consequent adverse effect on penalty loading. Special Civil Investigations (SCI) may also decide to take some forcing action to speed up the process.


It should be stressed that the adviser needs to be independent and thorough and must always be prepared to challenge the information provided by his client. It is in the adviser’s interest to ensure that the report is as factually correct as possible, and that independent verification has been undertaken where appropriate; the quality of his report will be considered by SCI as a measure of his ability and competence in undertaking this type of work.


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