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HMRC internal manual

Technical Teams Operational Guidance

HM Revenue & Customs
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Investigation work: Code of practice 9: investigation needed whilst disclosure awaited

Despite a disclosure proceeding satisfactorily there may be exceptional circumstances where some investigation needs to be done in order to ensure that HMRC’s interests are safeguarded.

Where documents or information are likely to be lost or destroyed we will take action under paragraph 2 Sch 36 FA 2008 in respect of third parties while the Disclosure Report is awaited. It will be very exceptional for us to need to consider taking action under paragraph 1 to obtain documents from the taxpayer whilst a disclosure is proceeding.