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HMRC internal manual

Technical Teams Operational Guidance

Case review and registration: developing the review: importance of identifying the wider implications of some potential investigations

Investigators should be aware of the possibility that the matter which is the subject of a Review may have wider implications.

Always try to get at the most serious area of potential tax loss in a Review and then consider the peripheral matters both in the case itself and in any other separate but related ‘spin-off’ cases.

Investigators should look beyond the obvious and try to understand the nature of what has actually occurred in a case. In large and complex cases this is not always easy. These cases may require the analysis of much information and the consideration, once the facts are known as clearly as they can be, of overlapping technical arguments.