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HMRC internal manual

Enquiry Manual

Working the Enquiry: Meetings: Establishing Culpability

You should keep the establishment of culpability in mind throughout the enquiry, particularly where the result of the enquiry seems likely to revolve around whether an apparent excess of private capital or insufficient means stems from diverted business profits. You may be unable to make up your mind finally about the extent of culpability until the closing stages of the enquiry, but do not allow the taxpayer and his or her agent to assume you have accepted lack of culpability in the meantime.

You should review critically any attempt to shift the blame for irregularities onto any other person, for instance the accountant or HMRC. Point out to the taxpayer that they signed the returns. Even if the figures have been completed by someone else, they remain responsible for their accuracy and have made a statutory declaration that the return is correct and complete.