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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: opening the investigation: form of opening letter in partnership cases

Whilst the Nominated Partner is responsible for submitting the partnership returns under Self Assessment (SA), responsibility for any tax liability falls to each individual partner and not the partnership.

If there are suspected fraudulent irregularities arising in a partnership, the opening COP9 letters offering a Contractual Disclosure Facility (CDF) should be addressed to the individual partners, as COP9 cannot be issued to a partnership. This also applies to Scottish partnerships.