Nudge letter theory: STEP Journal


10th February 2023

Danielle Ford, Head of Tax Disputes, and Riocard Hoye, Senior Manager, contributed an article to STEP Journal on HMRC’s activity surrounding Euro Pacific Bank nudge letters.

Whilst HMRC has access to more information than ever before, it lacks the resources to open full investigations into each taxpayer it identifies as a risk. Therefore, nudge letters are a cost-effective way for HMRC to communicate with a large number of taxpayers when it believes that a taxpayer’s affairs are not in order, and has identified a potential loss of tax. Our STEP Journal article explains why taxpayers with connections to Euro Pacific Bank must act quickly and seek professional advice as soon as possible.

There are some key things to note with nudge letters:

  • An advisor may not always receive nudge letters on behalf of their client.
  • A nudge letter is not a statutory enquiry into a taxpayer’s affairs.
  • Making a disclosure before receiving a nudge letter from HMRC leads to the most favourable outcome.

Read Danielle and Riocard’s insights in more detail in the full STEP Journal article here (subscription needed).

HMRC’s use of nudge letters is ever expanding and they have used nudge letters to cover a wide range of topics. We recommend that taxpayers immediately seek professional advice following receipt of an HMRC nudge letter, statutory enquiry or where a taxpayer has found a mistake in their filings to HMRC.  If you have any kind of dispute with HMRC then please contact Danielle Ford or Riocard Hoye.

Danielle Ford

Partner, Head of Tax Disputes & Resolutions
+44 20 7969 5591
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