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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: opening the investigation: reasons for registration not to be discussed

The letter offering the CDF should not indicate the reasons why the case has been registered for investigation.

If advisers query the policy, Investigators should refer them to the Code of Practice 9 which says:

“We will not usually tell you what our suspicions are: it is for you to decide to make a disclosure to us”.

This is because:

  1. An investigation under COP9 must give the taxpayer an opportunity to make a full and complete disclosure of any irregularities and minimise any penalties that may be due.
  2. In some cases our main suspicion might be information from a third party, the source of which can not be revealed to the taxpayer.

As a general rule, provided you are able to do so, you should only reveal evidence of your suspicions if you need to do so to progress the case. Where full co-operation and a complete disclosure are made, it should never be necessary to reveal the reasons for registration.