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Serious matter
Key points
- HMRC replaced its COP9 booklet on 14 June 2023 refreshing the process for correcting dishonest tax mistakes.
- Under COP9 HMRC offers taxpayers the chance to make a full disclosure of all tax irregularities through a CDF contractual arrangement in exchange for protection from prosecution.
- The process requires an upfront acceptance or denial of fraud by submitting forms to accept or reject HMRC’s offer of the CDF within ‘60 days from the date you receive the offer’.
- The revised COP9 places greater emphasis on co-operating with HMRC while retaining the threat of a criminal investigation if a full disclosure is not made.
- Risks for advisers and their clients of making mistakes during the COP9 process are considerable.
HMRC’s Code of Practice 9 (COP9) is a civil framework under which HMRC’s Fraud Investigations Service (FIS) investigates cases of suspected serious tax fraud. Many readers know of...
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