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HMRC internal manual

Specialist Investigations Operational Guidance

Statutory basis for closing an investigation: appeals: preparations

ARTG8000 gives advice on preparation for the appeal hearing. It is important to make the preparatory work as thorough as possible. The SI Appeals & Review team will provide detailed advice on what documents, statements and schedules we want to refer to at the hearing.

If any documents are not admitted they will have to be proved by a witness. For non-HMRC witnesses summonses may have to be issued.

HMRC is entitled to know what documents the appellant’s advisors intend to rely upon. Often, even in cases where fraud is contended, it is possible to agree that both sides will admit a lot of documents. These can form an agreed bundle of documents. There may then be further documents not admitted by one side or the other which will have to be proved.

Investigators should ensure they have consulted with the SI Appeals & Review team (see SIOG8330) at every stage and before agreeing to admit documents. If in doubt about any evidential or procedural matter get advice before it is too late.