The contractual disclosure facility (COP 9) is one of HMRC’s most important and cost effective tools in dealing with the more serious cases of tax evasion and suspected fraud. However, HMRC is changing its application in a way that risks reducing its effectiveness, write James Bullock and Ray McCann
The current government has displayed considerable determination to act tough in its fight against tax evasion. The announcement in the past few days that the contractual disclosure facility (CDF) is to be revised to offer taxpayers a much starker choice of either admitting or denying a fraud will be of great concern to advisers.
It should also be of concern to HMRC and the government since the CDF or Code...
