TTOG11490 - Civil Investigation of Fraud (Code 9): historical record: the opening meeting: the inducement

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At the opening meeting, you must make it clear to the taxpayer that if the conduct leading to the irregularities is still continuing, they must stop that conduct immediately and ensure that any disclosure covers all tax irregularities up to the date of the disclosure report. Failure to do so may adversely affect the reduction of any penalty that may be imposed if culpability is proved. If you have concerns over the risk to revenue caused by suspicions of on-going fraud and a lack of evidence of co-operation, you must take early steps to ensure that the disclosure process is managed robustly and in line with the guidance in TTOG11600 ‘Managing the disclosure process’.

Where the taxpayer acknowledges there are tax arrears, within his/her answers to questions, but does not admit to knowing it at the time, this is not to be seen as a refusal to adopt the procedures.

The disclosure process should continue and the taxpayer should be encouraged to provide a detailed and truthful explanation as to how the arrears arose. The most important thing is to be satisfied with the accuracy of the explanation provided. If you are not satisfied then you must conduct reasonable checks to test it.