AH0610 - Preparation for Hearing: Advice from Accountancy Units

Refer a prospective contentious appeal to Head Office - (Tax Administration Policy) if advice has been received from an Accountancy Unit.

Where

• you have received advice either orally or in writing from an Accountancy Unit and
• you propose to use, or may use, that advice at a hearing (either in arguing the appeal or by calling expert evidence) and
• the case has not been seen by the relevant technical specialist or that specialist is not, or may not be, fully aware of the involvement of the Accountancy Unit

submit the case to the specialist as soon as the need for a hearing becomes apparent.

The file should be sent with a report on the lines of ADB6.109 to Business Tax. The report should be sent before any arrangements are made for the appeal to be heard and should indicate the use it is proposed to make of the advice (including expert evidence) from the Accounting Unit.

Such a report will be regarded as meeting the requirement in AH0925 for a submission in cases of expert evidence generally.