HM Revenue and Customs (HMRC) will launch a Code of Practice (COP9) investigation where serious tax fraud is suspected. A COP9 is an opportunity for those suspected of tax evasion to secure a civil settlement and potentially avoid criminal prosecution.

The Contractual Disclosure Facility (CDF) can provide immunity to prosecution if the alleged fraud or evasion is admitted, you cooperate fully with the HMRC investigation and accept the terms of the CDF. Individuals can also request a COP9 investigation if they want to disclose deliberate tax evasion to prevent a criminal investigation.

How we can help

If you have received a COP9 letter from HMRC requesting full disclosure of your tax affairs, it is crucial you seek legal advice immediately. If you ignore the letter or reject the offer, HMRC is likely to launch a criminal tax fraud investigation which could, if you are found guilty, result in a custodial sentence.
Our tax investigations lawyers have helped numerous individuals navigate their way through a COP9 investigation to secure excellent outcomes. We have expert knowledge of the strict rules and timeframes governing CDFs and will assist in helping you provide full and accurate disclosure, mitigating the risk of prosecution to secure a favourable settlement.