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HMRC internal manual

VAT Accounting Manual

HM Revenue & Customs
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Stagger manipulation between associated businesses: role of the Senior Avoidance Investigator (SAI)

The local Senior Avoidance Investigator (SAI) should review any case before a direction is issued or any decision to withdraw monthly returns is communicated. It is the SAI’s role to review the recommendations of the reporting officer and consider whether the eligibility and all relevant facts have been taken into consideration, and that no irrelevant factors have been taken into account.

The SAI’s expertise in the area of identifying and evidencing an avoidance motive will be important in the decision-making process. The SAI’s involvement in these cases will also provide the consistency and equality of treatment that is required. The VPOT - VRAP Team remains available to discuss any concerns that officers might have.

SAIs are required to keep a record of the number of directions issued and refused and be prepared to provide the data when requested, either to the VPOT - VRAP Team, or to Anti-Avoidance group. In each case for which a direction is issued, a Tax Avoidance Scheme Advice (TASA) should be submitted to the relevant Lead Avoidance Investigator (LAI) in the normal way.