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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
, see all updates

Where CDF offer is made 30 June 2014 onwards: opening the investigation: initial approach to the customer

Once a case has been authorised for registration under COP9 the customer must be informed as soon as possible. You should write directly to the customer, with a copy to their authorised professional adviser. Your opening letter should include the following:

  • Copy of Code of Practice 9.
  • Contractual Disclosure Facility (CDF) contract incorporating an acceptance and rejection of the offer.
  • Copy of the Outline Disclosure document and guidance notes.

The opening letter asks the customer whether there is anything about their health or personal circumstances that may make it difficult for them to deal with your enquiries so that you can help. If the customer mentions that they have a disability you will need to ask them

  • what help they need, and agree any reasonable adjustments with them
  • whether they would like a friend, family member or support worker to attend any meetings with them.

The Equality Act 2010 requires us to make any reasonable adjustments needed to make sure a disabled customer is not treated less favourably than a non-disabled customer.

All opening letters to customers and their agents should be sent using the Special Delivery service.

A template for the opening letter can be obtained from SEES. The opening letter does not need to indicate if your concerns are with direct tax, indirect tax or both. However, if you are issuing COP9 in a case that is already under enquiry, you should indicate clearly whether any factsheets that have been issued previously have been withdrawn, superseded or still apply.

For direct taxes, you should consider whether Self Assessment enquiry notices are required.

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