The above discussion document which looks at the concept of a contractual disclosure facility within the framework of the civil investigation of fraud (CIF) has been published for comment.

Since the CIF procedure was redesigned in 2005 a significant number of changes have taken place within HMRC. This document explores one option for toughening and tightening HMRC's approach to CIF through the concept of a contractual disclosure facility.

The option included in the paper proposes:

• a formal “contract” for the CIF procedure, offered by HMRC to a taxpayer suspected of tax fraud, which would provide more certainty to those who wanted to work with HMRC;
• formality that would make it easier for HMRC to terminate the contract and short circuit the process for a taxpayer who refused to co-operate; and
• a facility for a taxpayer to make a spontaneous offer to HMRC to enter a contract to disclose.

Comments are requested by 20 September 2011.The discussion document can be accessed at http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_pageLabel= pageLibrary_ConsultationDocuments&propertyType= document&columns=1&id=HMCE_PROD1_031476