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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: opening the investigation: unrepresented taxpayers

It will be relatively unusual for a taxpayer to remain unrepresented after receiving the opening letter and Code of Practice 9 etc. In fact many taxpayers will appoint specialist advisers.

For those who choose to remain unrepresented, the onus falls even more on the investigator to ensure that the taxpayer is aware of their rights and the seriousness of the situation.