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ARTICLE · 21 JANUARY 2025

HMRC Investigations: Code Of Practice 9

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HMRC's Code of Practice 9 (COP9) offers taxpayers suspected of deliberate tax fraud an opportunity for voluntary disclosure, ensuring a civil settlement with no criminal prosecution or public exposure. The process involves cooperation, payment of dues, and guidance from specialists to minimize disruption

United KingdomCriminal Law
Maurice Martin
Maurice Martin
Jeff Millington
Jeff Millington
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Not all tax fraud in the UK results in a criminal investigation and prosecution. HMRC still has discretion to offer taxpayers whom they suspect have been involved in deliberate fraud an opportunity to make a full disclosure in return for a promise that the matter will be conducted under its code of practice (known as COP9).

At the present time, COP9 is the only facility open to a taxpayer in which HMRC will, in certain circumstances, offer a written guarantee of no criminal investigation. Specially trained officers within the FIS Directorate work the individual cases. Incidentally, 'FIS' (pronounced 'FIZZ') has nothing to do with champagne but stands for Fraud Investigation Service.

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