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HMRC internal manual

Technical Teams Operational Guidance

Investigation work: Code of practice 9: examining the disclosure report: incomplete report not amended

If the shortcomings in the Report are not put right promptly the Investigator should write direct to the taxpayer (copy to the adviser). The taxpayer should be told why we cannot regard the Report as a proper disclosure and told what needs to be done, within a defined period, in order for the report to be taken as the disclosure in response to CDF. He/she should be told that unless this is done within the time set this will be regarded as a failure to make a full disclosure within the terms of CDF.