HMRC Tax Investigations under Code of Practice 9

Code of Practice 9 (COP9) 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.

COP 9 investigations are conducted by senior HMRC officers within the Fraud Investigation Service. You can read more about teams within HMRC’s Fraud Investigation Service by visiting the link below:

Fraud Investigation Service

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 report under the Contractual Disclosure Facility. 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 the first opportunity to disclose any irregularities. Never attend an opening meeting without the support of a tax investigation adviser.

Admiral Tax is here to help

Admiral Tax can support you through the entire Code of Practice 9 (COP9) 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

Please seek specialist advice immediately.

Further important reading

Please do take some time to read through our detailed guidance on the investigation of suspected tax fraud below: