SCIG12420 - Reaching agreement on income or profit addition: Tax treatment: Tax treatment in Code 8 cases
In Code 8 cases, and those Code 9 cases where a technical argument is central, the Investigator has the initial responsibility of assembling HMRC’s technical arguments and rebutting unacceptable argument from the taxpayer and adviser. The Investigator must make use of all the information and expertise available within HMRC and consult the relevant technical experts (see SCIG03560).
The Operational Leader will be aware of what is occurring on cases on the Group but will only have time to be closely involved in the largest and most important.
The Operational Leader should make sure that appropriate advice is obtained from subject experts, the Technical Manager (Powers and Penalties) and Solicitors Office and that they are brought into the HMRC case team as soon as it becomes apparent that their input is or will be required.