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HMRC internal manual

Specialist Investigations Operational Guidance

Specialist areas: Finance Professionals Unit: contentious hearings

As soon as it appears likely that advice on an accountancy issue given by an FPU accountant will become the subject of a contentious hearing it will be necessary for the accountant to refer the advice to the Commissioners’ Advisory Accountant’s (CAA) team for approval in conformance with the CAA’s established procedures. The investigator will need to be aware of the impact this may have on progressing the case.