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HMRC internal manual

Specialist Investigations Operational Guidance

Investigation work: third party investigation work: commitments in SI Codes of Practice

SIOG1200 emphasises that the whole basis of HMRC’s approach to compliance work is to set out the fundamentals of their approach in Factsheets or Codes of Practice. Where you are working to a particular Code or Factsheet you must follow these in both letter and spirit. We advise the taxpayer, under ‘confidentiality’, of our basic commitments in third party investigation matters, and we make it plain that ‘we may have to ask other people or organisations for information relevant to our enquiries at any stage of the investigation.’

We tell the taxpayer however that:

  • ‘we will always do what we can to avoid someone else knowing that we want information in connection with a tax investigation, or embarrassing you in any way
  • we will only make third party enquiries if we feel it is necessary
  • when making third party enquiries we will pay proper regard to your business and personal interests and the need for confidentiality.’