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HMRC internal manual

Technical Teams Operational Guidance

Investigation work: opening under Code 8: disclosure reports

It is not the practice in dealing with Code 8 cases to seek a formal disclosure report although in some cases this may indeed be the best way forward. Care should be taken to ensure that a report really is the best way of proceeding. It is not uncommon for reports in COP8 cases to take several months to prepare and submit. Where such a report does no more than seek to justify the transaction, the investigator is likely to find that the investigation has become older with no progress being made.

In any case where it is thought that the commissioning of a disclosure report is appropriate, the Investigator should refer to TTOG11600 and TTOG4400 and TTOG4500.

It is more likely in a Code 8 case that any disclosure will be made during the course of the meeting or in a follow-up letter from the taxpayer’s advisers once they have had an opportunity to consider the points under enquiry.

Where the disclosure is made during the course of a meeting, this should be recorded in the notes of interview and an acknowledgement of this incorporated into the follow-up letter.