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HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: the initial meeting: questions to ask about customer’s private affairs

Whether the meeting with the customer is to

  • clarify an Outline Disclosure
  • commission a disclosure report, or
  • deal with a rejection or non cooperation case,

in addition to questions concerning the customer’s business affairs, you should consider asking questions about their private financial affairs where you believe this is appropriate.

This will help you to

  • understand the context in which the disclosure is made
  • explore the possibility of other tax risks
  • understand the linkages between the customer’s personal and business affairs
  • close off any unsubstantiated explanations of accumulated wealth, and
  • ascertain the living standards.

All of which will help you validate the contents of the disclosure report.

If there is more than one customer present they should be reminded again of their entitlement to confidentiality. If customers insist on being seen together then they may be seen on that basis, but if you feel that it is appropriate you should ask to speak to them separately.

In some instances you might well conclude that it is preferable to see each customer separately at some point in the interview. This could give a customer the opportunity to talk freely in case there is some matter they do not want to relate in front of a partner, co-director or spouse.