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HMRC internal manual

Specialist Investigations Operational Guidance

Information and inspection powers: Schedule 36 FA 2008: reasons not to be given

The occasions when the First-tier Tribunal might direct that reasons need not be given include cases of alleged fraud dealt with under Code 9 (CIF). At some stages of the enquiry it will be important for us not to reveal to the taxpayer how much we already know, in order to encourage a complete disclosure. (See TTOG11000 for more information on CIF.)

This provision is sensitive and it is important that it is not abused. Reasons should therefore be given unless there are compelling reasons for not doing so.

It may sometimes be possible to draft a summary of some of the reasons, and seek exemption only for the material that you believe must be kept secret. The tribunal might find this approach more justifiable than a total exemption.