April 12.

I refer to the article by Subhash Joshi in which he alleges that

''many smaller traders are being singled out'' for investigation by

Customs and Excise (Business Herald, April 1).

Mr Joshi claims that ''there is a growing tendency for VAT people to

target grocers, restaurants, chip shops, and takeaways for

investigation''. He also questions the fairness of specific methods used

by Customs and Excise investigators, e.g., covert observation in trying

to establish the true level of sales.

Within its allocated resources Customs and Excise has responsibility

to ensure as far as is possible that VAT registered traders of all

descriptions comply with their obligations under the law. Our policy is

to arrange for visits to newly registered traders wherever practicable

within 12 months of registration to ensure they are on the right lines.

We are also fully committed to the principles of the published

Taxpayers' Charter which sets out in simple language the standards to

which our staff are expected to operate, specifically to be impartial

and fair in our dealings with all VAT registered traders. The charter

also clearly sets out the various avenues of complaint and appeal

available.

VAT investigations are instigated for a wide variety of reasons but

often the starting point is an examination of the reasons behind cash

adjustments to annual accounts emanating from professional audit.

Mr Joshi is inclined to be dismissive of first-hand evidence gathered

from observation of premises. In the absence of adequate records this

method is very often the only recourse available to our investigators.

Although it is unrealistic to expect all traders to comply 100% with

the law, those who attempt to cheat the system will, as Mr Joshi

suggests, ''always be discovered''.

The commonly held belief that cheating the taxman is ''fair game''

takes on a different complexion when the consumer realises that it is

his/her money that is being ''siphoned off''.

Iain J. Matheson,

Press Liaison Officer,

Customs and Excise,

21 India Street,

Glasgow.