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HMRC internal manual

Technical Teams Operational Guidance

Code of Practice 8: consideration of potential tax avoidance in case registrations: the weight of actual or potential evidence suggesting tax avoidance

Given the wide variety of case types which may be worked under Code 8 there can be significant variation in the standard of potential evidence held suggesting that avoidance is present. Investigators should therefore exercise discretion and caution when recommending a case for registration as an Investigation.

The potential tax at risk will not be enough to convince an Team Leader to agree registration if there is little evidence to support the case being made and his or her experience will be an essential factor in deciding for or against registration.

Conversely situations exist where the evidence clearly points to avoidance being present and we can move quickly to register for investigation. In this type of case an admission is always welcome, however appropriate caution should be exercised, particularly as any disclosure involving an element of evasion may be more appropriate to the CDF process.

Occasionally, allegations are made by HumInts, often supported by documentary evidence, and whilst these cases will merit further review, we must be alert to the possibility that the HumInt is misinformed or acting out of malice.

Guidance on HumInts is at SIOG2100.