Settling the enquiry: agreeing income profit additions: technical arguments
In Code 8 cases, and those Code 9 cases where a technical argument is central, the Investigator has the initial responsibility of assembling HMRC’s technical arguments and rebutting unacceptable argument from the taxpayer and adviser. The Investigator must make use of all the information and expertise available within HMRC and consult the relevant technical experts (see TTOG3380).
The Team Leader should make sure that appropriate advice is obtained from subject experts, the Technical Manager (Powers and Penalties) and Solicitors Office and that they are brought into the HMRC case team as soon as it becomes apparent that their input is or will be required.
Where agreement overall is possible matters can proceed as described in TTOG5200, where it is not, as advised in SIOG8000.