Helen Adams and Andrew Park (BDO) on Gold Nuts Ltd and the interaction between HMRC’s contractual disclosure facility in cases where fraud is denied and a taxpayer’s human rights.
HMRC uses code of practice 9 (COP9) to investigate cases of suspected serious tax fraud. Such investigations start when HMRC issues an opening letter with an invitation to participate in the contractual disclosure facility (CDF) in exchange for an admission of fraud.
Some recipients of the CDF offer do not believe there is anything wrong with their UK tax affairs and others whilst being prepared to acknowledge issues believe that they made either innocent or careless errors not deliberate ones. When HMRC responds to their CDF rejection they may have questions about what follows next such as ‘will HMRC tell me what its concerns are?’ ‘do I have to provide more information?’...
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Helen Adams and Andrew Park (BDO) on Gold Nuts Ltd and the interaction between HMRC’s contractual disclosure facility in cases where fraud is denied and a taxpayer’s human rights.
HMRC uses code of practice 9 (COP9) to investigate cases of suspected serious tax fraud. Such investigations start when HMRC issues an opening letter with an invitation to participate in the contractual disclosure facility (CDF) in exchange for an admission of fraud.
Some recipients of the CDF offer do not believe there is anything wrong with their UK tax affairs and others whilst being prepared to acknowledge issues believe that they made either innocent or careless errors not deliberate ones. When HMRC responds to their CDF rejection they may have questions about what follows next such as ‘will HMRC tell me what its concerns are?’ ‘do I have to provide more information?’...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
