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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 other case situations

A partnership is not a taxpayer for the purposes of Income Tax Self Assessment. The letters of invitation to the opening CIF meeting in a partnership case where direct tax fraud is suspected should simply be addressed to the individual partners. There is then no need to link the partnership name to that of the partner in the same way as is necessary in the case of companies and directors. In cases where the suspected fraud relates to a liability of the partnership as a whole, and not to ITSA liabilities, then the letter of invitation should be addressed to the partnership.

In principle you should address letters to the personnel that are in an authoritative position within the business and/or also in a position where they should be (at least) aware of the fraud. If you are in doubt as to whom letters should be sent you should refer to the Authorising Officer for advice.