Code of Practice 9

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Code of Practice 9 (COP 9) Investigation Specialists

Home → Tax Investigations → Code of Practicee 9 / COP 9

COP 9 investigations are commenced by HMRC when they are suspicious 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 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).

This formal process starts with a letter from HMRC which offers the opportunity to make a full disclosure under a contractual arrangement. There are very 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.

Disclosure requires agreement to give complete disclosure of the full extent of the tax evasion. If so, HMRC will agree 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. Rejecting or ignoring the offer, or making an inaccurate disclosure are highly likely to lead to HMRC commencing a full criminal tax fraud investigation and prosecution.

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

Get in touch

If you have received a COP 9 letter from HMRC, contact our team without delay and speak to one of our COP 9 tax litigation lawyers.

Solicitor or Accountant?

If you are contemplating instructing a solicitor or an accountant on a COP 9 investigation, you should be aware that information you provide to your solicitor enjoys a special status known as legal professional privilege.

Your accountant is unable to provide this protection, although they could gain it if they are instructed by a solicitor. If there is to be an assessment of the tax due and a report prepared about your tax affairs, we can instruct an accountant on your behalf.

Who Can Help You?

Jonathan Wright


Mark Wilson, Partner at Richard Nelson LLP

Mark Wilson


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What we do...

We have an experienced team of COP 9 investigation lawyers & solicitors. We have had great success in resolving tax investigations as quickly as possible, whilst protecting your liberty, reputation and privacy and restricting the financial consequences you may face.

Our services:

  • Instant response to dawn raids, arrests and interviews under caution;
  • We will arrange advice and assistance for you, including meeting as appropriate, for all aspects of COP 9 investigations;
  • We will involve independent tax consultants, forensic tax accountants, and specialist tax barristers in your case if necessary, thanks to close working relationships that we have established with them.
  • Avoid a HMRC criminal investigation if one has not already started, by an appropriate and carefully managed disclosure to HMRC where appropriate;
  • Minimise the effects of an existing tax fraud investigation and endeavour to convert it to a civil solution;
  • Robustly defense of a tax fraud prosecution, including challenging Restraint Orders and Confiscation proceedings;
  • We act for taxpayers across England and Wales, including London (but not at London prices).

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