Code of Practice 9

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Code of Practice 9 (COP 9) Investigation Specialists

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Richard Nelson LLP’s team of specialist tax solicitors 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.

Many COP 9 investigations are commenced by HMRC – when they have evidence that a serious tax fraud has been committed or significant tax has been lost by deliberate conduct. It is offered as a one-off opportunity to use a civil solution for what is a 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).

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 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. Rejecting or ignoring the offer are highly likely to lead to HMRC commencing a full criminal tax fraud investigation and prosecution.

The ‘contract’ is that the taxpayer agrees to give complete disclosure of the full extent of all tax irregularities, and 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.

Our tax investigation team have significant experience and enjoy an outstanding success rate in assisting people facing a COP 9 tax investigation.

How our COP 9 investigation specialists can help


Get in touch

If you have received a COP 9 letter from HMRC, contact our team without delay and speak to one of our tax litigation lawyers. You can contact our team via the following means:

Solicitor or Accountant?

If you are considering contacting an accountant or a solicitor regarding a COP 9 investigation, you should be aware that information you provide to your solicitor enjoys a special status called Legal Professional Privilege (LPP).

LPP is a right that protects confidential relations between lawyers and clients and prevents them from having to be disclosed, even in court. This covers written and verbal communications to obtain and receive legal advice, and also communications when there is litigation or it is potential.

LPP only applies to lawyers and not to accountants or tax investigation advisers.

Who Can Help You?

Jonathan Wright


Mark Wilson, Partner at Richard Nelson LLP

Mark Wilson


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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 reponses 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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