If you have received notice from HMRC that it has initiated an enquiry into you or your company’s affairs under “Code of Practice 9”, you need to take it extremely seriously.

On issuing a COP9, HMRC offers a ‘Contractual Disclosure Facility’ (“CDF”), whereby HMRC will not pursue a criminal investigation into any tax fraud disclosed, so long as you make a full disclosure of tax irregularities under the CDF.

There are two stages to a disclosure and these must both be completed if you are to be certain that HMRC will not carry out a criminal investigation into the suspected tax fraud. Great care must be taken when seeking to comply with the CDF to ensure that any disclosure made is full and complete.

Taxpayers should always be professionally represented when dealing with a CDF COP9 enquiry. If you have recently been served a CDF COP9 enquiry notice, or you have an ongoing enquiry that you are not certain is progressing satisfactorily, please contact us.