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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
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Where CDF offer is made up to 29 June 2014: managing the detailed disclosure process: who is to prepare the detailed disclosure report

The content of the detailed disclosure report is always the responsibility of the taxpayer, as it is their disclosure. It follows that it is for the taxpayer to decide which professional adviser should undertake the preparatory investigation work and bring matters together in a disclosure report.

However, it is in everyone’s interest that this work is undertaken by someone who is competent and most importantly, who has the capacity to complete the matter within an acceptable timescale. Whilst the taxpayer is ultimately responsible for deciding who will prepare the disclosure report, if you have any concerns about the adviser’s ability, experience or capacity to complete the work on time you should raise this at an early stage. Generally speaking, it is better to do so when you are discussing the content of the report. Preparing a detailed report can be very demanding and an adviser less experienced in COP9 investigations might not be aware of the potential demands and strain that this can place on their firm.

You should also bear this in mind during the period that the report is being prepared and if you have any concerns then you should ask to meet more frequently than you might do where an adviser more experienced in preparing COP9 reports is acting.

It is never appropriate for an Investigator, even when pressed, to mention any firms of accountants or advisers as being recommended to prepare an investigation report for a taxpayer.