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HMRC internal manual

Technical Teams Operational Guidance

Investigation work: opening under Code 8: which advisers may be present at the opening meeting

The taxpayer is free to have representation from any adviser or advisers (qualified or not).

Frequently, where tax avoidance is evident, the taxpayer may have been encouraged to follow the arrangements by the professional adviser present at the opening meeting. Great care therefore needs to be taken in formulating questions to elicit the substance of these arrangements.