Code of Practice 9 (COP9) Investigation Solicitors

Many Code of Practice 9 (COP9 OR COP 9) investigations are commenced by HMRC in cases where there is evidence that a serious tax fraud has been committed. HMRC will follow the Contractual Disclosure Facility (CDF) route – previously known as ‘Hansard’ or Civil Investigation of Fraud (CIF) – when it has evidence of fraud but wishes to offer a one-off opportunity for civil solution to criminal tax evasion. Our COP9 investigation solicitors are well placed to support you should you be made such an offer.


Richard Nelson LLP’s team of specialist COP9 investigation solicitors are able to provide advice and representation if you need expert assistance with the investigative process or disclosure.

The COP9 formal process starts with an offer letter from HMRC providing the opportunity to make a full disclosure under a contractual arrangement. There are strict rules and time limits to follow. HMRC will not reveal what evidence they have. The taxpayer has to either accept or reject/ignore the offer within the timescales.

COP9 can also be requested by the taxpayer when they wish to make a voluntary disclosure of serious, deliberate irregularities. This can be a strategic move to avoid an anticipated potentially criminal investigation.

Whether you have already been contacted by HMRC – or you would like to submit a voluntary disclosure – it pays to have the support of specialists who understand the nuances of Code of Practice 9 and have assisted clients with similar proceedings in the past.

Contact our team today to discuss your case.

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COP9 investigation proceedings

Rejecting or ignoring the offer is highly likely to lead to HMRC commencing a full criminal tax fraud investigation and prosecution. This is why it is imperative to seek legal advice as soon as you receive a COP9 letter from HMRC.

The ‘contract’ is that the taxpayer agrees to give complete disclosure of the full extent of all tax irregularities. In return, HMRC agrees not to start a formal criminal investigation. Following full and accurate disclosure of the tax irregularities and supporting records, plus formal undertakings to this effect, there will be a civil settlement of tax plus interest plus penalty. Making an inaccurate disclosure is also highly likely to result in HMRC commencing a criminal tax fraud prosecution.

As a Leading Firm in The Legal 500, our team of specialist COP9 investigation lawyers have significant experience and an outstanding success rate in assisting people facing this form of tax investigation.

Reach out to us today.

How our COP9 investigation specialists can help

The COP9 tax investigation team at Richard Nelson LLP offers the depth and breadth of expertise required to achieve a successful resolution to your case.

We are well placed to support you, and can offer the following benefits by comparison to accountants or tax advisors:

  • Privacy and confidentiality: our lawyers have Legal Professional Privilege meaning all communications between them and their clients is confidential and cannot be disclosed without the client’s permission (unlike accountants or tax investigation advisers);
  • Carefully managed disclosure to HMRC where appropriate: our COP9 investigation specialists help you to avoid a HMRC criminal investigation (provided one has not already started) by a carefully managed disclosure to HMRC if appropriate;
  • Find civil solutions for existing tax fraud investigations: we can minimise the effects of an existing tax fraud investigation and help to convert it to a civil solution;
  • Robust defence of a criminal investigation or tax fraud prosecution – The robust defence of a tax fraud prosecution, including challenging Restraint Orders and Confiscation proceedings.

To discuss the support that you COP9 investigation specialists can offer, get in touch now.

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Our services in relation to COP9 investigations

When faced with a COP9 investigation, the support of an expert solicitor is invaluable. Our team has assisted many clients in situations like yours to achieve the right outcomes, and can offer the following services:

– Protecting you in Code of Practice 9 investigations;
– Making a proactive voluntary disclosure to avoid an investigation;
– Assessing the tax consequences (including challenges to what HMRC state);
– Drafting of responses to HMRC enquiries;
– Representing you and managing any meetings with HMRC;
– Tactics and negotiation to minimise penalties;
– Avoiding HMRC ‘naming and shaming;
– Conducting requests for Formal Reviews and Appeals to the Tribunal;
– Making formal complaints;
– Dealing with all contact with HMRC for you;
– Applying Legal Professional Privilege, and Solicitors’ Confidentiality as your safeguards.

Get in touch

If you have received a COP9 letter from HMRC or are considering voluntary disclosure, contact our team without delay and speak to one of our specialist COP9 investigation lawyers.

Specialist solicitors

Our multidisciplinary team is made up of specialists in a wide range of services, which means you'll always be represented by an expert in your area.

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Get in touch to arrange a no-obligation, fully confidential call to discuss your case and work out if you want to continue.

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Speak to solicitors in one of our offices throughout England and Wales, or arrange calls and remote meetings.


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