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Tricky business

17 March 2015 / Helen Adams , Jennifer Jones
Issue: 4493 / Categories: Comment & Analysis , Admin , Compliance , Investigations

Pitfalls that can arise for clients offered code of practice 9


  • HMRC offer many taxpayers suspected of tax fraud the opportunity to make a full disclosure in exchange for immunity from criminal investigation.
  • An outline disclosure of all deliberate errors and omissions must be made within 60 days of HMRC’s letter.
  • Specialist advice is often necessary particularly when a taxpayer does not believe he has made deliberate errors.

HMRC have a range of powers using civil and criminal investigations to deal with tax evaders and to recover the outstanding tax.

As the main focus is to recover revenue for the Exchequer after deciding whether to launch a criminal investigation HMRC offer most taxpayers suspected of serious tax fraud the opportunity to participate in the contractual disclosure facility (CDF) otherwise known as code of practice 9 (COP9).

The reasons for offering this include:

  • ...

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