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HM Revenue & Customs has long been criticised for failing correctly to notify a taxpayer's agent or accountant, when opening an enquiry - particularly under the new "Single Compliance Process".

While the Single Compliance Process (SCP) will be seen by many as a welcome improvement, in that it aims to

• tailor the enquiry process to the taxpayer - if less work is needed then this is identified early and should result in a relatively short (and therefore less costly) enquiry
• openly identify the specific risks or issues which concern the Inspector, if any
• deal with more types of tax simultaneously than the more traditional "one separate enquiry per head of tax" approach which has for so long frustrated taxpayers and their agents, repeatedly having to explain the business model, etc., to different Inspectors,

one of the more annoying aspects for agents was that the Inspector would by default engage directly with the taxpayer, effectively circumventing the tax adviser's official agency with HMRC - the right of representation being enshrined in the Taxpayer's Charter. (Or HMRC's Charter, if you will).

This has now been addressed and HMRC has announced that in future, SCP work (albeit notably only within Income Tax and Corporation Tax so far) will by default:

• Still write to the taxpayer first, asking if the taxpayer wants to deal directly with HMRC but
• If the taxpayer doesn't confirm within 7 days, the Inspector will telephone the agent to progress the case

While this change will be welcomed by tax advisers, the more cynical tax agents might have their own perspective on why HMRC has for so long resisted calls to include agents from the commencement of an enquiry, by default. So it is food for thought that HMRC appears still to want to give such priority to the opportunity to communicate directly with the taxpayer.

Agents will no doubt await the revised wording of that new letter, and implementation of the follow-up routine, with interest.