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HMRC internal manual

Technical Teams Operational Guidance

From
HM Revenue & Customs
Updated
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Code of Practice 8: consideration of potential tax avoidance in case registrations: additional yield in Code 8 cases

FIS should only be dealing with the larger more complex type of case. Whilst yield is not incorporated into targets, it can often be an indication of the quality of case being worked, but if FIS involvement can add little to what has already been established registration is probably inappropriate.

However there will be cases where the yield generated may be smaller but where the issue to be investigated is so important that FIS must become involved. A case of this type may be necessary as a test case perhaps flowing from a project where there would be industry-wide ramifications. If the issue is successfully addressed then other investigations arising can be handled by Local Compliance Offices following guidance from FIS. Other cases may be small but their complexity or importance may be such as to require the specialist input that only FIS can offer.

Where it is proposed to register a case which scores low in the Risk Assessment and specifically where estimated yield is low the Registration report should make particular mention of the reasons why registration is considered appropriate.