COP9 and tax investigations – what you need to know

Code of Practice 9 (COP9) is the most serious civil investigation by HMRC, only one step away from criminal prosecution. Danielle Ford, partner and Riocard Hoye, senior manager at haysmacintyre explain how to deal with a demand from HMRC

Receiving a COP9 and an offer to disclose under the contractual disclosure facility (CDF), is an extremely serious matter and represents the last civil chance for those who may not have paid the correct amount of tax.

What is a COP9?

COP9 is the code of practice under which HMRC’s Fraud Investigation Service (FIS) operates tax fraud investigations. COP9 is publicly available and details the parameters the FIS will operate under, the process, and potential consequences for failing to comply with the process.

What is the CDF?

CDF is the disclosure process which exists within COP9 for disclosures of deliberate tax fraud in exchange for immunity from criminal prosecution.

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