Code of Practice 9 (COP9)

HMRC’s most serious civil investigation type is the Code of Practice 9 (COP9), where HMRC suspects serious tax fraud. COP9 is usually commenced by HMRC but can be entered into voluntarily.

The COP9 process

An outline disclosure needs to be made to HMRC within 60 days of the COP9 enquiry being opened. This needs to contain as much detail as possible about all deliberate and non-deliberate tax irregularities. This document is of paramount importance as only irregularities disclosed here will be immune from criminal prosecution. Following this, an in-depth meeting will be held with HMRC to discuss the outline disclosure and in most cases, a full disclosure report will be commissioned after in which all irregularities will need to be fully explained with supporting evidence and disclosed to HMRC.

Seek professional tax advice

Taking professional advice in relation to COP9 is essential, given the fine margins which could lead to a criminal prosecution for an incomplete or incorrect disclosure. Our team includes Riocard Hoye, Senior Manager and a former HMRC Fraud Investigation Service (FIS) senior inspector who can offer unique insight into the process. We have a wealth of COP9 experience, helping our clients achieve their main aim of avoiding criminal prosecution but also assisting in negotiating a more favourable settlement in terms of penalty rates and payment arrangements.

We’ve written in detail about the COP9 process so if you have any queries, please contact Riocard or Danielle Ford, Head of Tax Disputes.

Danielle Ford

Director, Head of Tax Disputes & Resolutions
+44 20 7969 5591
View profile

Awards and Accreditations

eprivateclient top accountancy firm 2022

Get in touch