Tori Magill (Pinsent Masons) answers a query on a client who participated in a marketed avoidance scheme and has received a COP9 notice
Tori Magill reviews the changes to the contractual disclosure facility (CDF), and considers the impact for clients
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