Any matter being dealt with by HMRC under Code of Practice (COP9), which is sometimes referred to as “Hansard”, is a most serious matter. In a nutshell HMRC require the subject of their investigation to make a full and complete disclosure of all tax irregularities or face prosecution for fraud. These cases are reserved for officers within Civil Investigation of Fraud (CIF) teams or the Special Investigations (SI) teams. These officers are experienced and knowledgeable specialists.

The subjects under investigation may be individuals, their spouse or partner, businesses or companies, other family members of associates or fellow business partners or directors; which may mean that some cases have many areas of tax to consider and many ‘participants’ to consider them for.

In exchange for dealing with the matter on a civil basis HMRC require, within a very tight time-scale; a full disclosure to be made by way of a most detailed disclosure report. HMRC will test the report and in some cased COP9 has been withdrawn and a prosecution commenced where the disclosures made have been found to be materially incorrect or incomplete.

Managed correctly a COP9 investigation case is an opportunity to avoid prosecution and a criminal record. Furthermore, there are opportunities to obtain significant reductions in penalties and to keep any further intervention by H M Revenue & Customs to an absolute minimum. At the end of the process any general tax affairs will be up to date and cleared so that those involved can make a fresh start with real certainty for the future.

There are, however, many pitfalls for the inexperienced or under prepared and the protection offered under COP9 will be withdrawn if HMRC believe any disclosures are insufficient; our specialists have very considerable experience in dealing with these specific matters and have produced many effective disclosures on behalf of clients. You can be assured this experience is working for you.

We can help you understand what is required of you, by HMRC and by us, and we will manage the whole process on your behalf; reducing the need for you to be interviewed by HMRC officers as much as possible. We know what HMRC expect; we will investigate all matters, as necessary, to produce, on your behalf, an effective disclosure report, limiting the work HMRC may wish to normally undertake including any need for them to involve third parties such as your banks, customers or business associates.

We remain completely objective throughout the entire process; as will our advice and we will always present a robust defence of your position wherever possible. You will be informed and consulted at every stage. All disclosures and any settlement proposals will be discussed and agreed with you before submission to HMRC.

Our specialist knowledge and experience can also help us to achieve the best possible financial outcome on your behalf and as quickly as possible. We shall negotiate with HMRC for the best possible resolution and mitigation of penalties.