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HMRC internal manual

Technical Teams Operational Guidance

Civil Investigation of Fraud (Code 9): historical record: managing the disclosure process: scoping meetings and progress meetings

After the initial meeting, it is expected that the professional advisor who has been commissioned to produce the disclosure report will agree to hold a scoping meeting (normally without the presence of the taxpayer) so that the parameters of the disclosure report can be discussed and firm timetables agreed.

The scoping meeting plays a crucial role in managing the disclosure process. It gives everyone involved time to reflect on what was said or disclosed at the opening meeting, check understanding of some of the key issues, flag up potential difficulties in obtaining documents etc and then agree a course of action.

The scoping meeting and subsequent progress meetings not only act as an early warning system if things are not going to the agreed timetable (see TTOG11720 and TTOG4415) or the taxpayer withdraws his co-operation but also provides a source of regular contact with the professional advisor so that any common areas of difficulty can be addressed quickly and appropriately.

The intention at these meetings is to be helpful - it is in no one’s interest that a disclosure report is delayed or that plainly unnecessary work is undertaken. You must exercise great care in ensuring that you do not disclose our concerns, evidence etc of serious fraud or act in a way that could suggest that HMRC is investigating in tandem with the professional adviser.

The fact remains that once challenged under the CIF procedure, it is entirely a matter for the taxpayer to decide what is disclosed in response to the inducement.