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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: opening the investigation: at the outset we will not say what our concerns are

The detail of our evidence/concerns will not be disclosed to the taxpayer at the outset, as the procedure is to allow the taxpayer the opportunity to make a full disclosure under the Contractual Disclosure Facility (CDF) (see FCIM103050). We no longer need to indicate at the outset the tax regime or regimes under which our concerns lie.