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HMRC internal manual

Technical Teams Operational Guidance

Case review and registration: developing the review: third party work during the review - general

It may be necessary to carry out third party work before the registration decision is taken.

Some points are fundamental -

Whilst a case is a Review case no challenge should be made of the taxpayer.

The objective of third party work at the Review stage is to get as quickly as possible to the decision on whether or not to register the case. It is not acceptable to keep a case as a Review when it is really being worked as an investigation.

Care over confidentiality and discretion generally should always be exercised in third party enquiries. This is particularly so while the case is at the Review stage. This is because the taxpayer has not yet been notified of SI’s potential interest and has not had the opportunity to explain or provide information personally.