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The new Contractual Disclosure Facility

On 31 January HMRC launched its Contractual Disclosure Facility, the latest incarnation of HMRC’s civil investigation of fraud procedure. Phil Berwick reviews some of the practical issues arising from the new process.

HMRC launched its Contractual Disclosure Facility (CDF) on 31 January. The CDF is the latest incarnation of HMRC’s civil investigation of fraud procedure. This article considers some of the practical issues arising from the new process.

Why change?

The National Audit Office (NAO) condemned HMRC for the relatively large number of cases under the Civil Investigation of Fraud (CIF) process (the predecessor to the CDF) where taxpayers did not make a disclosure. This includes those who had no intention of co-operating with HMRC. Once the inspector...

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