Code of Practice 9 (COP9) Investigations

An investigation conducted under Code of Practice 9 (COP9 - through the Contractual Disclosure Facility) is incredibly serious and certainly should not be taken lightly.  Unlike most HMRC enquiries, a COP9 investigation covers not just one aspect of tax, but is extended to include any tax or duty that HMRC powers over.

To aid the understanding of such enquiries, we have recently updated our comprehensive guide to Code of Practice 9 Investigations.

As a result, this type of investigation can be intrusive and has a much broader range than a relatively simple compliance check. If you are subject to such an investigation you will be required to defend your behaviour against any suspicions that HMRC have that you have committed tax fraud, or take the opportunity to disclose any tax fraud that you have committed to HMRC.

Due to the serious nature of such an investigation and the suspicion of fraud, we at The Tax Faculty recommend that you contact us before you respond HMRC's opening contact so that our expert HMRC-handling specialists can provide you with the best possible advice on how you should proceed.

Indeed, HMRC themselves recommend that those placed investigation through the COP9 process seek specialist advice rather than rely on their usual accountant, as evidenced by point 1.2 of the COP9 document which is issued with their opening correspondence. 

Our experts have many years of experience in both conducting serious fraud investigations for HMRC as senior tax inspectors and also in defending clients from such investigations and allegations of serious fraud. By discussing your circumstances in a non-judgemental atmosphere with our specialists, we can give you detailed advice throughout the process.

Even if you do not eventually use The Tax Faculty, please do seek advice at an early stage. Whether you are an individual who has been accused of tax fraud by HMRC, or you are a private practice whose client has received an opening COP9 letter, please do not ignore the letter or attempt to respond without first seeking advice from professionals with the relevant experience.

We also offer our services to those who already have an existing COP9 investigation. Our experts can assist and give a new perspective on existing investigations, providing a pathway to navigate the investigation to a conclusion.

In addition to dealing directly with individual client investigations, our specialists have a proven track record of assisting independent practices in dealing with investigations into their clients.

It is sometimes overlooked, or not known, that the Contractual Disclosure Facility can also be used if an individual wants to bring their affairs up to date voluntarily and have the protection from criminal proceedings. Our experts can help people to disclose any failures to HMRC and discuss the best options available.

Our experts number industry award-winners for the way in which they handle COP9 investigations, making The Tax Faculty the best place for pragmatic advice. All initial consultations are free of charge as we know how confusing and complex such investigations can be, therefore we want to be sure that we are best placed to assist before you commit to our services.

We have also linked a guide to the beginning of a Code of Practice 9 Investigation for your information.