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HMRC internal manual

Specialist Investigations Operational Guidance

HM Revenue & Customs
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Statutory basis for closing an investigation: general: work cases recognising statutory powers may have to be used

Cases should be worked from the outset in such a way that if the statutory basis for closing the case becomes unavoidable we can move quickly and efficiently towards this point. It helps therefore to:

  • establish the facts of the case as far as this can be done
  • be clear about the provenance of documents to be used in civil proceedings
  • constantly keep in mind the time limits for assessments and determinations
  • draw up schedules and computations in a form that can be used directly - or with little modification - at a formal hearing
  • make it clear that any concessions made in informal negotiations are without prejudice (for example TTOG5330 negotiations within Technical Teams)
  • identify probable contentious cases early.