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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: the initial meeting: conduct of meetings and formal requests for information

At the start of the meeting it should be made clear that

  • the customer has been asked to attend on a voluntary basis
  • they are free to leave at any time
  • they do not have to cooperate, but the extent to which they provide information and help to resolve the investigation will be taken into account when deciding any reductions for the quality of disclosure for any penalty that is payable.

In explaining the format of any meeting and the procedures to be adopted, you must take into account the purpose of the meeting.

It is important to emphasise that at this point the interviewing officer is not exercising any powers. Any power, for example, requiring the production of certain documents, should only be exercised at a later stage if the voluntary procedure breaks down. It is not the intention that such powers are exercised at any initial meeting in cases where a Contractual Disclosure Facility (CDF) has been offered and accepted.

There should be a single meeting for all taxes. If the case covers several different taxes, officers with the relevant experience should be involved in the meeting. It would be wholly artificial to insist on separate meetings for separate taxes. The meeting should take place in a structured way. The first part of the meeting might, for example, focus on VAT. Once these matters have been dealt with satisfactorily it should then be explained that the interview is moving on to consider, say, Corporation Tax.