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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: the initial meeting: location of meetings

There are no prescriptive rules. The investigator should suggest where they believe the meeting should be held. The only requirement is that the venue should be one capable of supporting a confidential meeting for the number of people attending.

Providing the location is convenient for everyone, meetings can be held at HMRC offices, at the premises of professional advisers, at the business premises of the taxpayer, or at the taxpayer’s private house.

However, if the purpose of the meeting is to discuss the Outline Disclosure, you should bear in mind that the agent’s working papers may be central to your discussions. Therefore, in this situation the meeting may best be held at the agent’s offices. If the taxpayer (or agent) suggests that the meeting should be held elsewhere then you must ensure that the agent’s papers are available.

We cannot insist that any meeting is held at either the taxpayer’s business or private premises, nor indeed that the taxpayer attend at all. But your preferences can be made plain and the taxpayer and advisers can be told that there may be a significant saving in time and cost if the meeting is held at the venue of our choice.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)