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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: verifying the disclosure: incomplete disclosure

Generally speaking, as we are letting the taxpayer, or their appointed adviser, know what our concerns are (after the taxpayer has been given every chance to tell us) we should not get many detailed reports showing a material discrepancy between the disclosed arrears and what we suspect.

Whilst a taxpayer can not be prosecuted for tax irregularities disclosed under the terms of a CDF, there may be occasions when HMRC need to consider whether it is appropriate to commence a criminal investigation for frauds not disclosed. The terms of the CDF mean that a taxpayer can be prosecuted for the separate offence of providing a false certified document.

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