Fraud civil investigation - COP9 offer made with effect from 30 June 2014 - initial meeting

By Tolley
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The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Fraud civil investigation - COP9 offer made with effect from 30 June 2014 - initial meeting
  • Purpose of the initial meeting
  • The meeting

This guidance note provides an overview of the how the initial meeting between HMRC and the taxpayer will be conducted for all offers made with effect from 30 June 2014. This note should be read in conjunction with the Fraud civil investigation - COP9 offer made from 30 June 2014 - overview, Fraud civil investigation - COP9 offers made from 30 June 2014 - the disclosure and Fraud civil investigation - COP9 offers made from 30 June 2014 - closing the case guidance notes.

Purpose of the initial meeting

FCIM205000

The purpose of the initial meeting varies depending on the nature of the investigation, but normally one of the following will be the subject of the meeting:

  • discuss the contents of an Outline Disclosure and the scope of a detailed disclosure report if the taxpayer has accepted the CDF offer
  • discuss why the taxpayer has rejected the offer. HMRC will be expected to bear in mind that the customer may have evidence that supports the fact that they have not committed any fraudulent acts.
  • discuss why the taxpayer has decided not to cooperate with the investigation

HMRC should ensure that it adequately explains the purpose of the meeting to all of the parties involved so they can prepare for the meeting. HMRC will, however, take the opportunity during the meeting to confirm that the taxpayer is aware of the serious implications of not providing a full disclosure of the irregularities and the benefits of cooperating fully with the investigation.

HMRC will seek to achieve the following during the meeting with the taxpayer and their adviser:

  • ascertain the precise

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