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HMRC internal manual

Enquiry Manual

Working the Enquiry: Opening Meetings: Conclusion

Agreeing the scope of work to enquire into and quantify understatements

If understatements are admitted, you should establish, in general terms at least, their nature and extent. If it becomes clear at this stage that the case falls within the criteria set out at EM0364, you should not take the discussion further until you have submitted the case to the Evasion Management Team. In other cases, you should agree what needs to be done to enquiry into and quantify the understatements. You should seek the taxpayer’s co-operation in this, subject to explaining his rights under the HRA EM1362.

Make it clear to the taxpayer the extent of the information you will need to see, for instance all private bank and building society accounts.

The extent to which work is delegated to the taxpayer’s agent is a matter for your judgement given the circumstances of the case.