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HMRC internal manual

Enquiry Manual

Working the Enquiry: Opening Meetings: No Admissions

Where you hold information suggesting that the returns are inaccurate, if the taxpayer categorically denies that his or her returns are incorrect, you may disclose that information, but not the source.

In enquiries where one of the risks identified is the overall capital position or other risks identified in the Standard Intelligence Pack (SIP) you should say so. But do not give the taxpayer any indication of the amounts which need to be explained EM1838.

Where the taxpayer continues to deny any irregularities and you do not have other firm doubts about the returns, you should consider the information which you hold. How reliable is it? Can it be checked? If you cannot check it and other risks are limited, you may have to reveal the information you hold to the taxpayer or his or her agent. If it is still denied, you can only use your own judgement having met the taxpayer to tell whether or not he or she is telling the truth.

If the taxpayer denies irregularities and there are other risks attached to the returns, you should ask the taxpayer to provide other documents such as bank books or other records which you need. Where a taxpayer refuses to co-operate in such circumstances, you should consider issuing a taxpayer notice for the documents CH23500