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ISSUE 1
Jeni Morris
Jeni is a National Minimum Wage expert with unique insights and knowledge from her many years working within HMRC’s NMW team. She uses that wealth of experience to support businesses in mitigating the financial and reputational impact of ongoing or pending HMRC NMW investigations and to navigate the ever-changing regulatory requirements compliantly. Jeni is a regular speaker on NMW/NLW issues at regional and national conferences.
Question I have been in business for over 25 years and have been involved in many HMRC investigations throughout the years, however, this is the first time I have dealings with HMRC’s National Minimum Wage team. This NMW investigation has been ongoing for over 12 months and I really do not see the finish line yet! We have had a recent change of Compliance officer and they seem to be going right back to the Firstly, I am sorry you are having such a difficult time with this NMW investigation – the structure of a NMW investigation differs significantly from other HMRC investigations, mainly due to the fact that the compliance officers are undertaking a review to identify if any worker has been underpaid. Any arrears found will ultimately belong to an employee or former employee (not HMRC) and as such the whole process can feel very different.
start of the investigation and looking at all processes and practices again.
HMRC have already had 2 meetings with the business, numerous emails and calls with me, they’ve conducted employee interviews and asked for a mountain of data, but I still do not know if HMRC thinks the business has inadvertently underpaid any employee. What can we do?
NMW investigations can be lengthy too due to the mountain of evidence required by the investigating officer, they obtain the employer’s information, then have to cross-check that with a sample of workers’ interviews. If the employer does not have the evidence such as time and attendance records but the workers say they all work additional hours then HMRC may ask for additional statistical data such as computer system logging in/ out data, or
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