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HMRC internal manual

Specialist Investigations Operational Guidance

HM Revenue & Customs
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Investigation work: third party investigation work: third party investigation emphasised in SI

SI places a particular emphasis on third party information and investigation. In almost all SI cases there will be some third party aspect. In many cases analysis of third party information is crucial in the identification of the case in the first place but Investigators need to bear in mind the comment at TTOG4545 to avoid grounds for complaint.

It is often the quality of the third party investigation that distinguishes the exceptional case. Particular points of note are where the Investigator has:

  • used all sources of information during the period of the background research, prior to registration and subsequently, particularly imaginatively or innovatively
  • demonstrated a novel approach in perhaps identifying and approaching third parties where appropriate.

Third party work can be important in all types of SI case

  • many Code 8 cases are derived from Projects. Many of these will have developed along a seam of third party information or have been derived from an analysis of information provided by Risk and Intelligence Service (RIS), and the like
  • many Code 8 cases will go on to feature extensive third party work during the Investigation
  • Code 9 cases require third party investigation to allow us to be satisfied that a disclosure is correct and complete.