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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made up to 29 June 2014: the initial meeting: who should attend

Generally speaking, this will depend on the circumstances of the case (This content has been withheld because of exemptions in the Freedom of Information Act 2000) . Where the taxpayer attends a meeting and makes a useful contribution to the progress of the investigation, such behaviour will earn a reduction in penalty loadings. It is important to point out to a taxpayer who may be reluctant to attend, that they are thereby losing an opportunity to reduce the final penalty bill.

The taxpayer is entitled to have a solicitor (but not publicly funded legal advice as he/she is not being detained nor is the meeting at a police station) or an accountant/tax adviser present. Indeed where it is likely that you will require a more detailed disclosure report you should encourage the person who will be preparing the report to attend. However it is always a matter for the taxpayer to decide who they would like to have present.

It may be that where an agent has been appointed, the facts of the issue have been fully disclosed and the point to be discussed is one of the tax treatment based on the agreed facts. If so, then the agent may attend without the taxpayer.

Subject to that, in principle there should be at least two officers present at any meeting that is being held. HMRC staff numbers should not normally exceed those from the other side unless by prior agreement (for example to enable an HMRC Accountant to attend).