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HMRC internal manual

Compliance Handbook

How to do a compliance check: notes of meeting: introduction

Taking notes during a meeting

Where a meeting has been arranged with a customer, you must take notes. You should make it clear to those present that you are taking notes.

If you are using a tablet or laptop please follow the guidance at CH204100.

In order to optimise their evidential value you must follow the process outlined below to demonstrate the integrity of your original notes of meetings and visits when carrying out compliance checks:

  • All entries must be made in black ink using a ballpoint pen.
  • Caseworkers must not use gel, fibre-tipped, fountain or felt-tipped pens as the ink may leak into the paper and prevent both sides of the sheet of paper being used.
  • All pages must be numbered.
  • Any rough notes taken on separate sheets of paper must be numbered in the same sequence.
  • A new sheet of paper must be used for each new compliance check or meeting.
  • Notes should be made either at the time or immediately afterwards. The date and time they were written must be recorded at the end of the notes.
  • Each meeting or compliance check should be identifiable in the notes by the date, time and tax reference number. The name or names of any persons interviewed and the location should also be included together with the names of anyone accompanying you or the customer.
  • On completion of the compliance check or meeting notes you must rule off any unused lines with a Z and sign the notes. All unused space should be made unavailable to prevent anything being added later.
  • Any mistake identified at the time of writing must be scored through with a single line, initialled and the correct words inserted after the error. Correction fluid or other correction media must not be used to amend an entry.
  • Once completed all pages must be stapled or tagged together in order and stored securely.

If the process above is not followed then the accuracy and validity of the notes may be questioned at tribunal or in court.


Retaining and recording notes

All written notes of meetings must be retained for the required period of 6 years from 5 April following the date of closure of your compliance check.

Notes must be stored securely within the compliance check papers so that they can be retrieved if required for disclosure purposes or as evidence at a tribunal.

The main records of any compliance check should be within the Caseflow record or other case management system. Where Caseflow is used, and the business has agreed with the Scanning Team, the notes should be photocopied and the originals sent to Netherton to be scanned, (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

When you have received confirmation that documents have been successfully scanned you must destroy any photocopies.

Any completed notes taken out of the office must be tagged or stapled together to reduce the data security risks.

Amending information after signing the note

There may be exceptional cases where it is necessary for you to add or amend information after signing the note. If so, make a separate note indicating the reason for the addition or amendment and record the date that the addition or amendment was made.

Sending copies of notes to the person

In some cases, typed copies of the notes of the meeting will be sent to the person or agent. This action is usually taken when the compliance check involves potential income tax or corporation tax liabilities. Depending on the circumstances, the person or agent may be asked for their agreement and signature, and this should be mentioned during the course of the meeting. Any amendments which the person wishes to make should be set out in a separate document.

Notes must not contain non-common abbreviations or unsolicited, unprofessional or offensive comments. Any comments which you think are relevant beyond what was actually said must be recorded separately within Caseflow.

Further guidance on note-taking in direct tax cases is available at EM1833.

Further guidance on note-taking for indirect taxes and staff using notebooks is available at CH204080.