Skip to content

COP9 (HMRC Suspicions of Serious Tax Fraud)


Code 9 or "COP9" is an HMRC civil investigation route. 

Broadly, it is a last chance opportunity to regularise the tax position without going down the perilous criminal investigation route. This can be a voluntary decision or HMRC may have already opened an enquiry/tax investigation. 

Timing with candid/pragmatic advice is essential.


HMRC can and do fish...mere "suspicion" opens up information and access powers for HMRC investigators. They will not simply go away with a crafted letter. An evidenced-based approach is required by an experienced professional.

At times HMRC investigators lack technical appreciation of discovery statute. They are experienced and operate at a high level and we have estblished senior contacts.

Pragmatism is an essential ingredient in facilitating safe passage to reach a conclusion.

Essentially, we are advocates, defend clients and advise options together with entering into HMRC's Contractual Disclosure Facility ("CDF"). This is an entirely formal process and not a cost-free environment. It involves an adoption report. We shoulder the burden for the "temporarily adopted" client. 


The COP9 CDF process has stages which involve:

  1. Clearance from HMRC to trigger an HMRC CDF Offer;
  2. Materially complete Outline Disclosure of the tax fraud and other tax irregularities;
  3. HMRC CDF acceptance; 
  4. COP9 Scoping Meeting; and, 
  5. Proportionate, but robust Report.

The negotiated settlement is subject to HMRC scrutiny of the Report with Certification and a negotiated settlement exit. 

Case management of COP9 and HMRC Fraud Investigation Service (incorporating Proceeds of Crime/Criminal Taxes Unit) and dealing with such matters are shark-infested waters and unfamiliar territory for many accountants and other professional firms. 

With complex document-heavy cases involving multi-exit strategies these HMRC matters can quickly become time-consuming and stressful for the client and uninitiated. 

Our experience is technically extensive, but pragmatic in reaching a negotiated conclusion for those who are under HMRC scrutiny. 

We provide support and expertise including an effective strategy, preparing disclosure reports, negotiating exit settlements and penalty mitigation with time to pay. 

For those requiring a preliminary meeting please contact Chris Leslie. 

Chris leslie's background: With a First Class Honours in Computing Systems Analysis and 23 years experience, Chris took up an offer outside HMRC. Tax Networks Ltd was incorporated and for many years Chris has been advising/negotiating on the full spectrum of HMRC tax investigations to defend clients and regularise the position. 


M: 07852700634