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HMRC internal manual

Technical Teams Operational Guidance

The guidance: factsheets and codes of practice: use in investigations

SI Technical Teams operate under two published Codes of Practice.

  • Code of Practice 9 covers cases worked under the Civil Disclosure of Fraud (CDF) procedures, i.e. where serious fraud is suspected.
  • Code of Practice 8 covers cases which warrant investigation by SI (because, perhaps, a substantial amount of tax is at risk) but where the CDF procedure has not been invoked.

Before you register an investigation you must decide which Code of Practice (either 8 or 9) is appropriate. That code must be issued to the taxpayer at the start of the investigation.

Where the taxpayer has appointed an adviser, it may be appropriate to send the Code of Practice to them, but you should ask that it be passed onto their client.