HMRC COP9 Tax Investigation

Code of practice 9 (COP9) 

What do we know about HMRC COP9 tax investigations? (Also known as Code of Practice 9)  

Where HMRC suspect that tax fraud has occurred, they will investigate under Code of Practice 9 (COP9). If accepted into this process, the taxpayer must admit that they deliberately evaded tax and will be interviewed by HMRC officers from HMRC’s Fraud Investigation Service. 

These specialist COP9 investigators will offer the taxpayer a chance to correct all tax matters, not just the deliberate ones, by the submission of a disclosure report called the Contractual Disclosure Facility. The report should be prepared by a specialist in tax investigations and will be formally adopted by the taxpayer when it is submitted. In effect, the tax adviser will conduct the review and report all irregularities to HMRC in the report and calculate the tax, interest and penalties to offer HMRC in settlement. 

Upon receiving the report and settlement offer, along with certain formal declarations by the taxpayer, HMRC will test the contents against their intelligence and if they believe that the report is not correct and complete, they can reject it, ask further questions or take over the review themselves. 

The benefit for the taxpayer is that, if they are completely open and honest about all of their tax irregularities and submit the report on time and it is accepted by HMRC, they are guaranteed not to be prosecuted for any of the tax offences and irregularities admitted and disclosed in the disclosure report.

This gives the taxpayer a chance to have potentially criminal tax evasion dealt with under the civil procedure without fear of prosecution. 

We also offer our clients a fully supported Tax Investigation Service which is backed by an insurance policy that covers eligible fees should you be subject to a tax investigation  (however, please note that whilst our policy is comprehensive and we believe one of the best on the market, our policy does not cover COP9 enquiries).  Read how we support our clients through HMRC Tax investigations here.    

If you would like to discuss how Arram Berlyn Gardner LLP could assist you please contact us on 020 7330 0000 or email


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COP 9 is the last safe haven from prosecution for  those who have deliberately evaded tax. You don’t have to wait for HMRC to approach you, it is better to approach them first and seek admission to this code of practice

Dion Laycock

Dion Laycock

Tax Director
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