Commentary

A7.422 Steps in the investigatory procedure under COP8

Administration and compliance

A7.422 Steps in the investigatory procedure under COP8

A7.422 Steps in the investigatory procedure under COP8

Once a case has been classified as an avoidance cases which requires an investigative approach (see A7.420), the Fraud Investigation Service will register it as a Code 8 case. The case will then go through the following process:

  1.  

    •     the case will be formally opened and notification will be given to the taxpayer

  2.  

    •     an opening meeting will be arranged between the FIS officers and the taxpayer

  3.  

    •     the case will be progressed with further correspondence or meetings or visits

  4.  

    •     a payment on account may be requested from the taxpayer

  5.  

    •     the investigation will be drawn to a conclusion which is likely to include a financial settlement and the signing of a certificate of full disclosure

Opening of the COP8 case

Once a case is registered as Code 8 case the taxpayer will be notified. Where earlier contact has been made by telephone, a letter should always confirm this1.

The investigator should make it clear that the investigation is to be undertaken by FIS and a copy of Code of Practice 8 should be enclosed. Tax agents will be notified where appropriate. Where any open self assessment enquiries are to be included in the FIS Code 8 Investigation the wording of the notification letter should make it clear that is the case. Where there is a current self assessment return with no existing enquiry, the notice to investigate the taxpayers affairs will normally incorporate the written notice of enquiry required by Section 9A(1)

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial