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HMRC internal manual

Technical Teams Operational Guidance

From
HM Revenue & Customs
Updated
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Civil Investigation of Fraud (Code 9): historical record: verifying the disclosure: submission of the Disclosure Report

Ultimately, we would expect a Disclosure Report to be submitted. A full Disclosure Report should comprise a written narrative giving details of business activity, individuals involved, their roles and responsibility and an explanation of how any arrears arose. They should be supported by a schedule of arrears detailing the tax arrears and the methods and any supporting documents on how these arrears were calculated.

It is a matter for the taxpayer as to whether he or his representative prepares and submits the report. Where this is undertaken by the representative, the taxpayer is expected to complete an Adoption Certificate to state that they have read and agreed the report and sign both the disclosure report and the schedules.

A Report prepared by the representative that has not been adopted and signed by the taxpayer must not be accepted. It should be returned requesting that the taxpayer formally adopt and agree the disclosure. Similarly, any disclosure headed “Without Prejudice” should not be accepted.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
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  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Following receipt of a Disclosure Report taxpayers or advisers may ask for the investigation to be limited. Taxpayers may ask that the bank, particular suppliers or clients/customers should not be approached because to do so would adversely affect their business. Taxpayers and advisers can be told that all third party investigations are conducted with sensitivity and a third party enquiry will only be made if it is considered to be necessary.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)