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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: pre-authorisation review and action: suspicion of fraud

When a case is under review, it is not always possible to reach a conclusion on whether or not fraud has actually occurred; not all of the facts may be known. Though evidence held may suggest fraud, it will often be untested. As part of the review process, you should be looking for the strength of evidence to demonstrate your suspicion of fraud.

You should keep an open mind at all times. Your judgement should be directed to the question of whether or not there is a reasonable suspicion of fraud to justify recommending that the case be registered under COP9.

The amount of evidence potentially available suggesting that a fraud has occurred will vary significantly from case to case. For some cases there will be strong evidence at the outset suggesting fraud, but for others, there will be less. In all cases, when the review is concluding, you must consider whether or not a reasonable suspicion of fraud exists.

Following on from HMRC making the CDF offer, the way in which the case develops and is settled will depend on what is disclosed in the Outline Disclosure.

Where the customer, or their agent, contacts HMRC requesting the offer of a CDF, as they have a tax fraud to disclose, refer to the guidance at FCIM202020.