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HMRC internal manual

Specialist Investigations Operational Guidance

Opening under Code of Practice 8: third party investigation

The potential difficulties associated with third party work can hardly be overstated, particularly in cases where the taxpayer disputes that anything is wrong.

This is a sensitive area and it is important to recognise that enquiries might create commercial risks. Detailed guidance is given in SIOG6100 and this must be referred to if third party enquiries are considered necessary.