Code of practice 9 investigations

HMRC has been using code of practice 9 and the contractual disclosure facility more widely in recent years. If you’re faced with an investigation, our team has the experience and inside knowledge to help you achieve the best outcome.

HMRC carries out investigations where they suspect tax fraud under code of practice 9 (COP9). Under this code, HMRC offers the taxpayer the opportunity to make a full disclosure under a contractual arrangement called the contractual disclosure facility, or CDF. The investigation may cover your indirect and direct tax affairs. The contractual disclosure facility provides the opportunity to disclose any irregularities along with the reasons they arose, which can help you reduce any penalties that may become due.

HMRC continues to investigate HSBC Swiss account holders and other cases using COP9 and the CDF. Traditionally, such investigations have only been used where HMRC is virtually certain that a disclosure of irregularities will be made.

Following the closure of the Liechtenstein disclosure facility and the crown dependencies disclosure facilities, taxpayers with significant undisclosed tax liabilities should consider using the CDF as a way of voluntarily correcting their past tax affairs.

Our team of tax dispute resolution specialists has considerable experience of dealing with HMRC enquiries under COP9 and using the CDF. Please do not hesitate to get in touch with us on +44 (0)800 032 8374.