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HMRC internal manual

Specialist Investigations Operational Guidance

Investigation work: mandates: when to request a mandate

Mandates authorising the Investigator to approach third parties (including banks and other financial institutions) will often be requested in Code 8 and Code 9 cases but this is not exclusive to technical teams.

However we do not require a mandate in order to investigate and we should never give the impression that we will refrain from contacting a third party simply because a mandate is refused. We will always though try to proceed with the taxpayer’s co-operation, and that will normally mean that mandates will be requested. If that request is declined then we will, where required, approach third parties without a mandate using third party information powers if that becomes necessary.