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HMRC internal manual

Technical Teams Operational Guidance

HM Revenue & Customs
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Case identification: basic principles: case criteria

This chapter is concerned with case identification. Subsequent chapters are concerned with the processes of review and case working.

FIS Technical Team’s primary work areas and additional specialist work areas are set out in the Special Investigations Operational Guidance

The main themes, covering both direct and indirect taxes are:

  • avoidance cases which require an investigative approach
  • cases involving suspected serious fraud which will be dealt with under civil procedures

These themes are not mutually exclusive. Examples of the work we deal with are:

  • cases that require sensitive handling such as ‘Sensitive’ cases, people in the public eye and others where there is likely to be media interest
  • substantial investigations involving individuals or groups of companies with liabilities spread across several areas or with other special features including marketed/bespoke avoidance
  • cases of particular difficulty or importance in the field of personal taxation
  • cases where there is evidence that groups or classes of employees or self-employed are involved in avoidance or evasion
  • cases involving particularly complex or difficult records examination requiring accountancy expertise
  • cases which will require extensive use of the information powers, in particular where third party enquiries are needed
  • cases where the Contractual Disclosure Facility (CDF) procedure is considered appropriate

Investigators and team leaders need first to identify cases which are within these broad criteria. They then need to decide whether the case is appropriate for FIS (in terms of seriousness, size, expected value, etc) and if it is, under what code it should be worked.