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HMRC internal manual

Technical Teams Operational Guidance

Case identification: basic principles: substantial tax at risk

Where fraud is not thought to have occurred, SI will consider the tax that is at risk through evasion, avoidance or non-compliance.

The tax at risk will be all HMRC duties of any kind plus interest and penalties that are likely to become due and collectible following SI action, less those duties etc that would have been collected without any SI intervention.

When considering tax at risk the Investigator has to bear in mind the prospect that in some cases only a fraction of the duties correctly enforceable are likely to be recovered. Company liquidation, insolvency or bankruptcy of an individual does not mean that SI’s interest is abortive or at an end. It does mean that a judgement of the likely yield or worth of the case must take into account the actual prospects for recovery and not just what is assessable on paper.

For COP8 registrations are expected to be appropriate to the skills and resources of SI Technical Teams.. See also TTOG3000 regarding risk assessment of review cases.