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HMRC internal manual

Specialist Investigations Operational Guidance

Statutory basis for closing an investigation: appeals: liaison with Solicitor's Office

In SI cases, the appellant at a contentious appeal is frequently represented by counsel. Normally the case for HMRC will be taken by an advocate from the SI Appeals & Review team.

Where the nature of the case is such that the Appeals & Review Team Leader feels that the HMRC case should be taken by a solicitor or counsel they will authorise this and there should be early liaison with Solicitor’s Office. This may be particularly relevant where the case turns on a technical point in the legislation rather than an instance where the tribunal is being asked to rule on factual circumstances.