What should a tax adviser do if his client refuses to make a full disclosure to HMRC?

What happens if HMRC makes an error in favour of the taxpayer?

How should a tax professional respond to a request for information from HMRC?

The answer to these and many more questions can be found in the 2004 edition of Professional Conduct in Relation to Taxation (PCRT), issued on 30 April 2004 by the five tax and accounting professional bodies (click here to view). PCRT provides practical guidance for members on dealings with the tax authorities. It covers areas such as disclosure of irregularities, requests for information from a new adviser, investigation of tax accountants, materiality and HMRC errors.

The 2004 edition updates the guidance last issued in 2000 and in particular addresses the changes introduced by the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2003 and developments concerning legal professional privilege.

The Tackling Tax Avoidance - Disclosure Requirements initiative announced in this year's Budget could have a significant impact on the tax profession. Although too late for inclusion in this edition of PCRT, guidance will be issued by the professional bodies on this topic in due course.

The parts relevant to IIT members will also be contained in the new Ethical Rules and Practice Guidelines shortly to be finalised and issued to members.