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How to handle COP 9: our top nine steps

Despite its critics, the COP 9 process appears to be here to stay. Sarah Stenton and Lisa Vanderheide (Stewarts) provide practical insights for advisers.

Code of Practice 9 (‘COP 9’) enquiries are serious. COP 9 is the common acronym for enquiries carried out by HMRC under the civil disclosure of fraud (CDF) process and via HMRC’s Fraud Investigation Services (FIS) team. HMRC opens a COP 9 enquiry where it suspects fraud and is prepared to settle the tax liability civilly rather than criminally.

One valuable ‘advantage’ to a person under enquiry via COP 9 is that it gives them the comfort that they will not be prosecuted for the tax fraud as long as the COP 9 process is adhered to and full disclosure is made.

When a person receives a letter offering them the opportunity to disclose tax fraud via the COP 9 process it...

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