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HMRC internal manual

Specialist Investigations Operational Guidance

Statutory basis for closing an investigation: general: statutory powers may have to be used to achieve conclusion

Most cases end by agreement.

However the type of case SI works is such that agreement will not always be possible. Once it is clear that agreement may not be achieved it is necessary to work the case towards conclusion using statutory powers. We may have to assess, amend a self-assessment, or determine or assess penalties. All of these may be contested. See EM3952 and SIOG8000 for further advice.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)