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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: the opening meeting: visiting the taxpayer’s premises

At some point in the enquiry you may decide that it will be useful to visit the taxpayer’s business premises, in order to inspect them, and to inspect the business records and business assets. You have the right to do this under paragraph 10 Sch 36 FA 2008, subject to safeguards and procedures. Full guidance on the use of this inspection power is given in the Compliance Handbook, and it should be followed carefully.

Depending on the case, an inspection may be appropriate after the opening meeting, as part of the verification of a disclosure report, or where you are carrying out the investigation yourself. But such a visit should never be seen as a matter of routine, and most cases will not require a visit at all.

Exceptionally, it may be worth while inspecting the taxpayer’s private premises. For example, such a visit may provide assurance about the taxpayer’s lifestyle, in a case where defalcations have to be quantified by reference to outgoings. This visit may only be made at the taxpayer’s invitation, and you should make it very clear that you do not have the power to inspect premises that are not used for business purposes.

Note that it may often be necessary for HMRC to make visits outside the CIF procedure, while the CIF enquiry is continuing, for example to check on the current application of PAYE and VAT rules. The CIF procedure only applies to tax etc. becoming due before the date that the procedure commenced. The existence of a CIF enquiry should not be allowed to curb reasonable assurance visits focusing on later liabilities.