SIOG8120 | Statutory basis for closing an investigation: general: work cases recognising statutory powers may have to be used
From HM Revenue & Customs · Specialist Investigations Operational Guidance
Cases should be worked from the outset in such a way that if the statutory basis for closing the case becomes unavoidable we can move quickly and efficiently towards this point. It helps therefore to:
establish the facts of the case as far as this can be done
be clear about the provenance of documents to be used in civil proceedings
constantly keep in mind the time limits for assessments and determinations
draw up schedules and computations in a form that can be used directly - or with little modification - at a formal hearing
make it clear that any concessions made in informal negotiations are without prejudice (for example TTOG5330 negotiations within Technical Teams)
identify probable contentious cases early.