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HMRC internal manual

Technical Teams Operational Guidance

Investigation work: Code of practice 9: examining the disclosure report: consideration of private capital position

The starting point is the Disclosure Report. Where this contains private side reviews and capital statements these should be tested by the Investigator. Each case should be considered on its merits.

In a simple (not necessarily a ‘small’) case nothing much may be gained beyond checking the report and observing the build up of private capital plus estimated expenditure compared to known income. This might particularly be the case where the irregularities are known to be on the Business Side and predominantly non-extractive.

In other cases meticulous private side investigation can unlock the case, lead back to the Business Side of the investigation and take matters on to further stages. The Investigator has to use judgement after getting the feel of the case.

An Investigator may have to draw up Capital Statements or re-cast those in the Disclosure Report. Single entry Capital Statements may be put into a double entry format for the whole, or part of the investigation period.

Inexperienced Investigators should get advice and, where work is undertaken, get assistance, as required, from SI Accountants and support staff. Work in this area can be very time consuming so it must be well directed.