Code of Practice 9 (COP9)

It may be useful if you begin by reading our essential guide Code of Practice 9

HMRC Tax Investigations under Code of Practice 9

Code of Practice 9 is a UK tax investigation procedure that HMRC use in cases where they suspect serious tax fraud. The procedure is incredibly intense, stressful and intrusive. You should never attempt to deal with a case conducted Code of Practice 9 without advice and representation from a UK tax investigation specialist.

Code of Practice 9 cases are conducted by one of two specialist HMRC teams:

  • Special Investigations
  • Civil Investigation of Fraud

There are key differences between these two teams. Visit our dedicated pages on null and civil investigation of fraud by clicking on the relevant links.

20 year disclosure

Code of Practice 9(COP9) enables HMRC to formally investigate your tax affairs over a 20 year period. However, their initial approach is to give you the opportunity to disclose any problems yourself. This comes in the form of a full disclosure report. A disclosure report under Code of Practice 9 is a time intensive, hugely technical and an incredibly far reaching piece of work. You need to ensure it is both accurate and comprehensive. In fact it would be fair to say that it needs to be watertight.

In their opening Code of Practice 9 letter, HMRC will recommend that you seek representation from a tax investigation specialist. It is advice you should heed. They will also ask you to attend an opening meeting, where you will be given first opportunity to disclose any irregularities. Never attend an opening meeting without the support of a tax investigation adviser.

Admiral Tax are here to help

Admiral Tax can support you through the entire Code of Practice 9 process.

We will:

  • Review your tax position thoroughly
  • Negotiate the scope with HMRC
  • Work with you to complete a full disclosure report
  • Attend all meetings with HMRC
  • Negotiate a final settlement, including tax, interest and penalties
  • Secure you time to pay if appropriate
  • Advise you on future good practice

Regardless of scale if you:

  • Have received a letter from HMRC Special Investigations or civil investigation of fraud, informing you that they are investigating you under Code of Practice 9
  • Have been asked to make a full disclosure of your tax affairs
  • Have concerns regarding tax fraud or tax evasion generally

… then you should seek specialist tax investigation advice without delay.

Get in touch

You can reach a Code of Practice 9(COP9) specialist by calling Admiral Tax on 0330 999 5000. You may prefer email, in which case we will respond to any questions or concerns you have within the hour.