TTOG11740 - Civil Investigation of Fraud (Code 9): historical record: managing the disclosure process: payments on account

In all cases where a disclosure is being made the taxpayer should be invited at the opening meeting to consider making a general payment on account. It is the best way a taxpayer can demonstrate his co-operation. This is a key element of the CIF procedure and should be encouraged in all cases.

The payment on account should not exceed a reasonable estimate of the additional tax or duties due. Taxpayers must understand that a realistic payment on account is part of what is envisaged when a disclosure is made in response to the CIF Statement.

Where the taxpayer does not have the immediate means to make a payment on account, arrangements should be put in place to realise assets, to bring money back from offshore etc as quickly as possible. In some cases a regular instalment may be arranged.

In principle, any payments received should be dealt with in the following manner:

• an acknowledgement of receipt should be given to the taxpayer
• if a payment is received in advance of any assessment being raised forms will need to be completed, in accordance with guidance for each individual tax.

The payment, together with the completed forms, should be sent to Accounts Office.

In encouraging the taxpayer to make payments on account you should advise them that this will be beneficial for them as it may reduce any interest that is due on the ultimate assessment and that this effort on their part to clear any debt at the earliest opportunity will help influence any request for time to pay that may subsequently be needed.

Payments on Account are held on a ‘without prejudice’ basis.