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HMRC internal manual

Technical Teams Operational Guidance

Investigation work: opening under Code 8: venue of opening meeting

There are no prescriptive rules. The Investigator, in completing the Registration Report, should suggest where it is felt the opening meeting should be held.

The basic requirement is that the venue should be one capable of supporting a confidential meeting for the number of people attending.

Meetings can be held at SI Offices, at local tax offices, at the professional premises of advisers, at the business premises of the taxpayer or at the taxpayer’s private house. Where any meeting is at a taxpayer’s house the Guidelines for visits to a taxpayer’s private residence should be followed (see Special Investigations Operational Guidance)

We cannot insist that the opening meeting is held at either the taxpayer’s business or private premises. We can legitimately make our preferences clear and we can emphasise to the taxpayer and his or her advisers that there may be a significant saving in time and cost if the meeting is held at the venue of our choice.

Meetings may be held outside the jurisdiction but certain rules must be followed. If a SI Investigator proposes official travel abroad - which includes the Channel Islands and the Isle of Man - the Deputy Director’s authority must be obtained in advance. A brief report explaining the need for the trip should be made for his/her benefit in considering the request; the outcome of the visit and any particular features that might lead to adverse comment should be reported similarly.

Note that meetings must not be held in Switzerland. It would be against Swiss law unless permission were given by the Swiss authorities.