The chapter considers to what extent tax investigations are like, and how they are unlike, police investigations. It examines the powers available to HMRC in the investigation of evasion offences. The bifurcated regime operated clearly in the enforcement activities of Customs and Excise and the Inland Revenue from the earliest times. At the time (early 1980s) of the Keith Committee, before the Police and Criminal Evidence Act 1984 (PACE) and before the significance of the civil/criminal distinction (in terms of the European Convention on Human Rights) was recognized in English law, police powers were ill-defined and did not allow for a clear comparison to be made between the sorts of rules that might circumscribe the investigations if the objectives were solely (a) to investigate crime or (b) to establish the tax position of the taxpayer. Over time, the investigatory powers have become increasingly closely assimilated to the PACE powers.
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