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HMRC internal manual

Technical Teams Operational Guidance

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

It will be relatively unusual for a taxpayer to remain unrepresented after receiving the opening CIF letter and Code of Practice 9. In fact many taxpayers will appoint specialist advisers.

For those who choose to remain unrepresented, the onus falls even more on the investigator to ensure that the taxpayer is aware of their rights and the seriousness of the situation.