CONTRACTUAL DISCLOSURE FACILITY (COP9)

The Contractual Disclosure Facility is used by HMRC to investigate suspected cases of tax fraud. All such enquiries are dealt with under Code of Practice 9 ( http://www.hmrc.gov.uk/admittingfraud/cop9.pdf)

With the exception of criminal prosecutions, COP 9 investigations are the most serious type of HM Revenue & Customs (HMRC) enquiries. COP 9 investigations – which can cover corporation tax, income tax, capital gains tax, PAYE and – typically occur when HMRC believes it has strong evidence of under-declared tax but will choose not prosecute if the taxpayer co-operates with its investigation.

The two bodies of offices within HMRC who carry out these investigations are the Special Investigations offices, who deal with cases where significant amounts of tax or serious issues are at stake, and the Civil Investigation of Fraud offices, who take responsibility for enquiries where smaller sums of tax are thought to be at stake.

On issuing COP9, HMRC offers a ‘Contractual Disclosure Facility’ (“CDF”), whereby HMRC undertakes not to pursue a criminal investigation into any tax fraud disclosed, so long as you undertake to make a full disclosure of tax irregularities, under the CDF.

Anyone identified by HMRC for a COP9 investigation needs expert advice. Our experts are mainly ex-HMRC investigators and inspectors who understand the HMRC mindset and have used their skills for many years to achieve the best results for clients.

Please contact for free initial advice.

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