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When the Inland Revenue launch an enquiry into a taxpayer’s returns, there may or may not be a suspicion that there is anything wrong – it could be a random check. The bottom line is that even if there has been an omission or error which has triggered the enquiry, there is a basic assumption on the part of the Inland Revenue that the taxpayer has not deliberately or constructively tried to pay less tax than he owes. However, if – in the course of the enquiry – the Taxman discovers possible evidence to suggest that the taxpayer has either not complied with tax law in a positive effort to pay less tax or not reported revenue or costs honestly, then the enquiry can become an investigation. This then becomes a completely different ball-game, with the ultimate objective being not just the recovery of the unpaid tax, interest and penalties, but also the possibility of criminal charges.