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HMRC internal manual

Specialist Investigations Operational Guidance

Case identification: unprompted disclosure cases: unprompted disclosure to SI

Taxpayers or their advisers may approach SI directly with a view to making an unprompted disclosure.

The relevant guidance should be followed and the Team Leader must be consulted on the appropriate course of action before any commitments are made. No discussion of facts should be held unless and until it becomes clear that the case can be dealt with outside CDF. It is highly unlikely that this will be the case. The Assistant Director or Deputy Director may give instructions to Team Leaders on the circumstances in which they need to be made aware of unprompted disclosure cases.

Where an offshore account or asset is the subject of disclosure, you will need to ensure that the disclosure is not proper to a publicised offshore disclosure facility or an initiative where the Offshore Coordination Unit has primary responsibility.

All unprompted disclosures which fall outside of CDF guidelines or are not part of an offshore disclosure initiative should be recorded in the Propriety Register (SIOG9420). You must always be mindful that direct tax might not be the only issue. The individual might already be the subject of an indirect tax enquiry, excise enquiry or an enquiry by another authority (for example the police)