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HMRC internal manual

Specialist Investigations Operational Guidance

Introduction and organisation: recording information: audit trail

All of the major decisions on a case - registration, agreeing profits, penalty loadings, and so on should be set out in writing and be readily identifiable and accessible. This is not a sign of weakness or ‘back covering’; it is vitally important in all cases. Even a number of years after a case has been settled, SI must be able to provide an audit trail of why and how the case was worked and concluded the way it was.

Decisions on penalties now need to be recorded on a ‘PDAC’ form (Penalty Decision and Action Checklist). See CH407050. Penalties also need to be recorded on NPPS (National Penalties Processing System) see CH401250.