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HMRC internal manual

Technical Teams Operational Guidance

HM Revenue & Customs
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Investigation work: Code of practice 9: examining the disclosure report: requesting additional papers from the advisor

Advisers adopt different policies in the construction of Disclosure Reports. We do not dictate a particular format. Some advisers submit with the Disclosure Report all analyses, working schedules, photocopies of the most relevant back-up documents etc in a series of Appendices to the Report itself. Others send in what is essentially a summary of conclusions and the principal schedules.

We should obtain all of the back-up documentation, bank etc. accounts analyses, and working schedules when they are not supplied. If the adviser objects to the production of these papers he/she should be reminded that the bank analyses are an essential part of the Report and that if necessary an order could be sought under paragraph 1 Sch 36 FA 2008 requiring the taxpayer to produce the information contained in the documents.

We do not expect to see notes of the adviser’s discussions with the taxpayer, nor of any legal advice