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HMRC internal manual

Technical Teams Operational Guidance

Case review and registration: arrangements for taking SA responsibility: where some participants in an SI Investigation are subject to an SA enquiry and some are not

There are likely to be a number of situations where some participants in an SI case (of whatever Code) are within SA while other participants in the same case are not. The most common situation is where some participants have been identified as UK non-resident individuals and companies, and who consequently have not been issued with an SA return.

A decision will also have to be taken as to when ITSA and CTSA enquiries need to be opened on a company and its directors. There may be timing consequences to bear in mind and in case of doubt refer to the Enquiry Manual .

Our Codes of Practice 8 and 9 are drafted to be broader than just to cover an enquiry into an SA return. The same, appropriate, Code of Practice can therefore be given to a participant in one of our cases who is subject to SA, just as it can to one who is not.

What we must do is to make sure that all participants are informed as to where they stand with SI and HMRC generally.