Code of Practice 9

HMRC’s most serious civil investigation type, where tax fraud is alleged from the outset. COP 9 is usually commenced by HMRC but can be entered into voluntarily.

An outline disclosure needs to be made to HMRC within 60 days of the COP 9 enquiry commencing. This needs to contain as much detail as possible about all deliberate and non-deliberate tax irregularities and 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 this, in which all irregularities will need to be fully explained with supporting evidence and disclosed to HMRC.

Taking professional advice in relation to Code of Practice 9 is essential, given the fine margins which could lead to a criminal prosecution for an incomplete or incorrect disclosure. Our team includes a former HMRC Fraud Investigation Service (FIS) senior inspector who can offer unique insight into the process. We have a wealth of COP 9 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.

Danielle Ford

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

Awards and Accreditations

Get in touch