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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: preliminaries to the opening meeting: reasons for registration not to be discussed

The letter of invitation to the opening meeting should not indicate the reasons why the case has been registered for investigation. If advisers query the policy, Investigators should refer them to Code of Practice 9 which says “we will not reveal to you the information we hold that has given rise to our concerns” because an investigation under the CIF procedure gives the taxpayer an opportunity to make a full and complete disclosure of any irregularities.

However the invitation letter should include an indication of the tax regime (indirect tax or direct tax) and in the case of indirect taxes only, the head of tax or duty to be discussed at the meeting (e.g. identifying a particular company within a group registration and a particular tax regime within that company).