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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: pre-authorisation review and action: limited companies

There will be particular cases where the person able to make a financial settlement may not be the person who committed the serious fraud. Examples could include board members, new directors/shareholders where it was the previous incumbents who committed the fraud.

Each case should be considered on its merits and discussed with the Authorising Officer, taking into account the nature of the fraud, alternative procedures for investigation available and the conduct of the current office holders, eg whether they were complicit with the fraud or failed to inform HMRC of it at the earliest opportunity.