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HMRC internal manual

Technical Teams Operational Guidance

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HM Revenue & Customs
Updated
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Investigation work: Code of practice 9: disclosure reports

Most Disclosure Reports arise in Code 9 cases when commissioned by a taxpayer under the Contractual Disclosure Facility (CDF). See TTOG10040 (Appendix 8)

The material in this section describes the action to be taken to obtain such a report. The Fraud Civil Investigation Manual (FCIM) contains detailed guidance in managing the disclosure process.

Reports may be invited or offered in Code 8 cases. These should be distinguished however as there is no necessary implication of fraud or culpability.

In Code 8 cases we may reveal the nature of our concerns. In CDF cases we do not. So in a CDF case we do not discuss what the report should specifically cover whereas in a Code 8 case we can say what matters should be included.