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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
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Where CDF offer is made up to 29 June 2014: opening the investigation: form of opening letter in other cases

Whilst the Nominated Partner submits the partnership returns under Income Tax Self Assessment (SA), it is the partners themselves and not the partnership that are liable for any liabilities.

If there are suspected fraudulent irregularities arising in the partnership, the opening COP9 letters offering CDF should be addressed to the individual partners, as COP9 cannot be issued to a partnership.

The letters should include the name of the partnership.