»Ê¹ÚÌåÓýapp

Where either:

• the taxpayer advises HMRC that they are not going to cooperate or
• HMRC does not hear anything within the time allowed,

HMRC will need to reconsider the earlier decision not to pursue a criminal investigation, with a view to prosecution. »Ê¹ÚÌåÓýapp case should be referred to Criminal Investigation (CI) for further review.

If the eventual outcome is that we should pursue a civil investigation the taxpayer should be informed in writing (with a copy to the agent). »Ê¹ÚÌåÓýapp taxpayer will not have any assurance that the fraud will not be the subject of a criminal investigation. »Ê¹ÚÌåÓýapprefore, if further material evidence comes to light that the investigator thinks might cause CI to reconsider their original decision not to prosecute the tax frauds or there is new evidence of a false document or statement, then the investigator should refer the case to their authorising officer to consider if a further referral to CI is appropriate.