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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: the initial meeting: advice on confidentiality

Where there is more than one customer present at any meeting they should be told at the start that HMRC has a duty of confidentiality. The meeting will be wide ranging and could cover both business and private matters. Each customer should be asked to confirm that private financial details can be discussed with all present. The customers should be invited to indicate at any point during the meeting if they would prefer to answer questions without others being present.

The remarks about confidentiality should still be made regardless of any relationship between the customers.

If any customer wants to be dealt with separately from the outset then matters should be arranged accordingly.

You may also need to consider confidentiality if there are different agents representing different types of tax. An example of this may be when a customer wishes to discuss both company and private affairs and he has different agents acting for his personal and business affairs.

Occasionally, you might encounter situations where a customer does not feel free to say that they would like to speak to you separately. Therefore, you should consider advising them that they can contact you after the meeting, by telephone, if there is anything they would like to discuss in private (but always be mindful of the need to make sure that your actions can not be interpreted as seeking to exclude their agent). See the guidance at FCIM205070.