Code of Practice 9

Many Code of Practice 9 (COP9 OR COP 9) investigations are commenced by HMRC when they have evidence that a serious tax fraud has been committed. This is usually when they have the evidence but offer it as a one-off opportunity for civil solution to criminal tax evasion. This was originally known as ‘Hansard’, which then became the Civil Investigation of Fraud (CIF), and is now the Contractual Disclosure Facility (CDF).


Richard Nelson LLP’s team of specialist tax solicitors are able to provide advice and representation if you need expert assistance with a COP 9 investigation or disclosure. Contact us today to find out more.

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.

The COP 9 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.

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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 part of The Legal 500 for 2021, our team of specialist tax investigation lawyers have significant experience and an outstanding success rate in assisting people facing a COP 9 tax investigation.

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How our COP 9 Investigation Specialists can help

– 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 – Helping 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 – Minimising the effects of an existing tax fraud investigation and helping 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.

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If you have received a COP9 letter from HMRC, contact our team without delay and speak to one of our tax litigation lawyers.

What we do

– 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.

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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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