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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: action following issue of Code of Practice 9: the civil investigation

There will be cases where the fraud disclosed is relatively straightforward and easy to quantify and very little further work is needed to finalise matters. Where this is the case we will look to resolve matters as quickly as possible by:

  • asking the taxpayer to make their formal disclosure (FCIM104095)
  • agreeing what is owed
  • arranging payment.

In such cases, we do not usually envisage that the taxpayer will need to attend a meeting. Any meeting required would normally be with their appointed adviser.

In most cases, however, we will want to see a good deal more detail before we can accept that a full disclosure of all irregularities has been made, and before it is appropriate to ask the taxpayer to sign the certificates which comprise a formal disclosure (that is, Certificate of Full Disclosure, Statement of Assets and Liabilities, Certificate of Bank Accounts operated and Certificate of Credit Cards used). In these cases, we will ask the taxpayer to arrange for a Disclosure Report to be prepared and to adopt it as their report of irregularities.

We will investigate thoroughly any case where:

  • an incomplete Outline Disclosure is made
  • irregularities are denied
  • the taxpayer is not going to cooperate.

Once we decide that this will be a civil investigation, how it proceeds will depend on the particular circumstances of each case. However, we will usually seek an early meeting.