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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: managing the disclosure process: who is to prepare the disclosure report

This can be a difficult area. The content of a disclosure report is the responsibility of the taxpayer who is making the disclosure. It follows that it is for the taxpayer to decide which professional adviser should undertake the preparatory investigation work and bring matters together in a disclosure report.

It is in everyone’s interest however that this work is undertaken by someone who is competent and who has the capacity to complete the matter within an acceptable timescale. The taxpayer is ultimately responsible for deciding who will prepare the disclosure report.

It is never appropriate for an Investigator, even when pressed, to mention any firms of accountants or advisers as being recommended to prepare an investigation report for a taxpayer.