CoP9 Code of Practice 9  COP9 – Contractual Disclosure Facility

COP9 (Code of Practice 9)

What is CoP9?

A COP9 – Contractual Disclosure Facility (CDF) enquiry is HMRC’s most serious civil investigation. It means HMRC suspect you of committing tax fraud, a criminal offence. Specialist, highly experienced and trained officers from HMRC’s Financial Investigation Service (FIS) will undertake the work. The COP9 allows you to enter a contract with HMRC to make a full disclosure of any tax offences you have committed and settle the arising liability by way of payment of the taxes, interest, and penalties to avoid a criminal investigation. It is a very serious matter and requires specialist advice from receipt of the letter offering the CDF.

 

How can we help?

We have extensive hands-on experience of the COP9 enquiry process from working in HMRC and the tax profession. Consequently, we are perfectly suited to helping you in resolving what will be an intrusive, demanding and in-depth enquiry into your personal and business affairs. We will get to know you and your personal and business tax circumstances, exploring with you why HMRC have the suspicion of tax fraud. We can then:

 

  • Advise you on the best course of action, whether that be to make a disclosure or, if appropriate, deny any commission of tax fraud. We ensure that you are aware of the consequences of the course of action which applies to your circumstances.
  • Prepare the outline disclosure to accept the CDF offer and progress the HMRC enquiry.
  • Represent and support you at any meeting required with HMRC going forward.
  • Engage with HMRC to manage the disclosure and prepare the required disclosure report for submission on your behalf.
  • If a denial is made of any tax irregularities, we will engage with HMRC to resolve their concerns which generated the initial CDF offer.
  • Ultimately, we will progress the enquiry to the best settlement achievable on your behalf.
  • Throughout the process, we will consult with you and your professional advisors to ensure you are kept fully informed on the progress of the enquiry.

 

Have you a question or enquiry?