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HMRC internal manual

Specialist Investigations Operational Guidance

Introduction and organisation: recording information: notes of meetings

Notes of meetings are a vital record of what takes place at them and can be very important at some later stage in the investigation. You should note:

  • Where the taxpayer attends a meeting, you should normally send the notes to the taxpayer (care of the adviser if there is one). You should ask the taxpayer for written confirmation of their agreement to them. However where the meeting is only a technical discussion with an in-house taxation department, you need not issue notes for formal agreement unless you want to for a particular reason or the taxpayer and/or adviser requests it.
  • All HMRC officers who attend a meeting with a taxpayer should sign and date the notes.
  • You should always record any informal conversation you have with a taxpayer (for example, during a break in a tribunal meeting or at a house visit) and place the note on file. Allegations are sometimes made, long after the event, of improper remarks or action by an investigator in these situations. A contemporaneous note of these conversations is a safeguard.
  • It is best to draft and finalise all notes of meetings as quickly as possible after the meeting has ended. If, for any reason, there is a delay in finalising them, you should note the date of the draft as a footnote to the final notes.
  • You must retain preliminary, hand-written notes of a meeting or telephone conversation. This is particularly important if the case becomes contentious or is referred to Criminal Investigations.
  • You should always date and sign preliminary, hand-written notes so that it is clear who made them and when.
  • Final notes may well differ from preliminary notes. It is perfectly proper not to include something noted down in preliminary notes which later turn out to be unnecessary.
  • You must ensure that the final record is a full and fair record of what occurred at the meeting.
  • You must not amend final meeting notes. If the taxpayer or adviser suggests changes, you should record these and sign and date them on a separate sheet. If you later believe that the facts are different to the way they have been recorded in the final notes, you should prepare, sign and date a separate note.
  • You must not change preliminary manuscript notes made at a meeting.
  • There is no place for ‘off the record’ discussions. You must make a note of any ‘without prejudice’ discussions.