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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: preliminaries to the opening meeting: arranging the initial meeting

It is likely that the taxpayer or representative of the taxpayer will contact you prior to the initial meeting. This provides an opportunity for you to:

  • confirm the date, time and venue of the meeting
  • establish if the taxpayer will be represented
  • if not, suggest to the taxpayer that they may wish to give some thought on this point (this could help avoid a cancelled meeting)
  • establish if there are any language barriers, consideration can then be given as to the need for an interpreter
  • assess the likelihood of the taxpayer accepting the procedures.

It is not unusual for tax representatives to request a pre-meeting meeting. These are informal meetings held without the taxpayer (but with the taxpayer’s authority), which allow the representative to raise any issues or concerns prior to commencement of the procedures. In most cases these can prove useful, but you must use your knowledge of the case and the representative involved to decide whether there is likely to be any benefit in attending such a meeting. Such requests should be treated with care. Frequently the adviser’s motive in seeking a preliminary meeting is to try to glean some information from HMRC as to why the case has been registered. This information is not to be given. There is no obligation to justify the registration decision to an adviser; permitting a debate on the issue is usually ill advised because it will divert attention away from the CIF challenge to the taxpayer which invites a full and complete disclosure.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000) You should use the meeting to ensure the representative fully understands the procedures and to give them the opportunity to outline any specific circumstances, where forward consideration may benefit the application of the procedures. You must not allow the representative to use the meeting to seek to deviate from the procedures or obtain further information on your reasons for the investigation or the method of investigation.