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HMRC internal manual

Technical Teams Operational Guidance

Code 9 cases registered prior to 1/9/05 (Hansard): Historical Record: the opening Hansard meeting: immediate response not forthcoming

Where a disclosure is not forthcoming some further explanation may be given. This needs to be handled carefully. The Hansard policy itself must not be paraphrased or compromised.

We do not need to disclose our reasons or any evidence held at the opening meeting. COP 9 makes it clear that we will not disclose our information at the Hansard meeting. If the case did proceed to court then we clearly would need to disclose our evidence before getting to court but not at the opening meeting. The Court of Appeal in R v Gill & Gill endorsed our current practice saying the former Revenue “was not bound to disclose the nature of its suspicions and there was nothing unfair in its not doing so”.