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Official guidance
Specialist Investigations Operational Guidance

SIOG8100 · Statutory basis for closing an investigation: general

  • SIOG8110 · Statutory powers may have to be used to achieve conclusion
  • SIOG8120 · Work cases recognising statutory powers may have to be used
  • SIOG8130 · The taxpayer may initiate statutory powers
  1. Statutory basis for closing an investigation: general: contents
  2. Statutory basis for closing an investigation: general: work cases recognising statutory powers may have to be used

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.

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