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HMRC internal manual

Technical Teams Operational Guidance

Case review and registration: developing the review: analysis by the investigator and SI support staff

There is no mandatory procedure to be followed. Everything depends upon the nature of the case.

In many cases no detailed analysis beyond an assimilation of the facts and a consideration of the merits of the case need be made. In others the case cannot be understood without analysing the available information.

In some cases the best option may be to return the case to its originating office with advice for them to finish the analysis of the taxpayer’s business and private capital position.

If the case warrants it, however, analyse the case thoroughly within SI. This should not be done as a matter of course.

SI support staff may undertake some of the primary analysis work. This is often the most efficient use of resources. Investigators may work jointly with an SI accountant in reviewing the business records (and outside accountant’s working papers if these are available) and decide what programme of further analysis needs to be undertaken.

In a different case our analysis might take a wholly different form. The point at issue might not be extractive fraud but who exercises control over a particular company.

It may be necessary to trawl through material in order to establish the shareholdings of successive tiers of a company structure. We may then have to present this in a form that shows the links/connections between individuals. Considerable scheduling or computer analysis and subsequent graphic presentation may be required.

Analysis work can be very time consuming. It must always be kept specific to the needs of the case. It must always be directed, when undertaken in a Review case, to reach a conclusion on whether or not the case can be registered.

Review work in general and analysis work in particular must be focused and have an objective.