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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: preliminaries to the opening meeting: form of invitation to opening meeting in company cases

The letters of invitation to go out in company cases should normally refer in the heading to the company and the individual director(s). This is in order to make it clear that it is the director both as an individual and as an officer of the company who is being addressed in the CIF statement. Both the individual director and the company itself are subject to investigation under Code of Practice 9.

The linking of the director with the company in correspondence may have important evidential consequences if appeal proceedings ensue. It is not unknown for objections to be raised to the introduction in company appeals of correspondence headed only with the director’s name and vice versa.