The Contractual Disclosure Facility
is a tough new regime to improve the COP9 investigation process, says
Jeff Millington
With effect from 1 February 2012, Code of Practice 9 (COP9)
investigations were changed considerably.
In the commentary below, the changes are considered together
with the impact it will have for those who come under the investigation
regime.
The important changes are:
HMRC will issue a formal invitation to persons to
enter into the contractual disclosure facility (CDF) and make full
disclosure;
the department will allow a 60-day period so that
a detailed outline of the disclosure may be made;
an initial formal opening meeting will no longer always
take place;
and unlike the previous regime, criminal proceedings
may now be used by HMRC even though the CDF has been offered.
