Understanding Code of Practice (COP 9) Investigations
Introduction to Code of Practice 9 and the Contractual Disclosure Facility

Code of Practice 9 (COP 9) is a procedure used by Her Majesty’s Revenue and Customs (HMRC) in the UK to investigate cases where serious tax fraud is suspected. It allows taxpayers to disclose any irregularities or fraudulent activity related to their taxes under the Contractual Disclosure Facility (CDF). By making full and accurate disclosure, individuals and businesses can avoid criminal prosecution. Templeton Brook Witt provides expert guidance, comprehensive disclosure preparation, and representation in negotiations with HMRC. With the support of Templeton Brook Witt, you can ensure effective handling of tax investigations under COP 9 and further improved tax compliance.
The contractual arrangement of the current version of COP 9 is called the CDF. If the taxpayer agrees to, and completely follows its conditions, they will avoid criminal prosecution. In situations of intentional misconduct, HMRC has the authority to look back up to 20 years to recover unpaid taxes, alongside additional interest and penalties for late payment. Depending on the tax amount and disclosure quality, individuals could find their information publicly listed on HMRC's website as deliberate tax defaulters. At Templeton Brook Witt, our
tax investigation specialists aid in preparing vital documents and liaising with HMRC, ensuring clients avoid legal entanglements.
Stages of the COP 9 Tax Investigation Process
The COP 9
tax investigation process begins with an initial notification from HMRC, outlining suspicions of tax fraud. It provides essential details about HMRC's concerns and sets the stage for further communication and CDF plays a pivotal role, allowing taxpayers to voluntarily disclose irregularities to avoid prosecution. Accepting the CDF entails committing to full disclosure within a 60-day period. Templeton Brook Witt assists clients in navigating this process, ensuring comprehension of obligations and maximising the potential for a favourable outcome. With our assistance, clients can approach COP 9 investigations with confidence, maximising the potential for a favourable resolution while mitigating risks and penalties.
When faced with potential tax irregularities, it's essential to navigate the disclosure process effectively. Firstly, assess the scope by reviewing finances, including income, expenses, and offshore assets or income that haven't been disclosed. Next, gather relevant documents like financial records and receipts, bank statements, and any other evidence that supports your disclosure. With the information collected, prepare a comprehensive disclosure statement detailing all tax irregularities. Be sure to provide clear explanations for each irregularity and include supporting evidence wherever possible. Templeton Brook Witt’s
tax investigation specialists assist in preparing thorough disclosures and navigating HMRC interactions. AT Templeton Brook Witt we ensure clients comply effectively and negotiate favourable outcomes.
HMRC's Investigation Process: From Disclosure to Settlement
Upon receipt of a COP 9 disclosure, HMRC launches an extensive
tax investigation. Firstly, HMRC meticulously reviews the disclosed information to understand the nature and extent of tax irregularities, scrutinising supporting evidence. Next, HMRC may conduct interviews with relevant individuals to clarify details and gather additional information crucial for the investigation. Additionally, HMRC may request further documentation to validate the information provided in the disclosure and gather additional evidence. Throughout this process, HMRC aims to gather sufficient evidence to determine the extent of tax fraud and assess appropriate penalties or enforcement actions. At Templeton Brook Witt we provide expert assistance throughout the investigation process.
Upon receiving the disclosure, HMRC will conduct a thorough review. Complete and accurate reports, coupled with full taxpayer cooperation, prompt HMRC to aim for a settlement covering tax underpayment, interest, and penalties. COP9 penalties may reach 100% of evaded tax, but factors like disclosure quality and timeliness can mitigate penalties. Are you ready to navigate tax investigations confidently? Trust Templeton Brook Witt. Our expert
tax investigation specialists offer guidance and ensure thorough disclosure preparation, effective negotiation with HMRC, and maximum penalty mitigation. Don't face tax investigations alone.
Get in touch with Templeton Brook Witt today to safeguard your financial future.

Don’t Face HMRC Alone: How Templeton Brook Witt Can Protect Your Business During a Tax Investigation

