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Changes to COP9

15 July 2014 / Hannah Wickstead
Issue: 4460 / Categories: Comment & Analysis , COP9 , Investigations

Why HMRC reduced taxpayers’ options during civil investigations of fraud

The contractual disclosure facility (CDF) was introduced as part of the code of practice COP9 process in January 2012 to improve HMRC’s ability to tackle tax evasion.

The department undertakes criminal investigations of tax offences where necessary and appropriate. It does not criminally investigate every time: many cases of suspected tax fraud are investigated using civil powers under COP9 instead.

When a taxpayer accepts an offer of CDF HMRC expect their full co-operation an admission of deliberate conduct and settlement of all outstanding liabilities including penalties. In return HMRC agree not to open a criminal enquiry into the deliberate conduct in question.

If the taxpayer rejects the terms or does not respond HMRC may undertake a criminal investigation with a view to prosecution. If the taxpayer makes a partial disclosure HMRC reserve the option to proceed with a criminal enquiry on any undisclosed information. There...

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