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ARTICLE · 20 FEBRUARY 2023

HMRC Investigations: Code Of Practice 9

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Not all tax fraud in the UK results in a criminal investigation and prosecution. HMRC still have discretion to offer taxpayers whom they suspect have been involved in deliberate fraud an opportunity...

United KingdomCriminal Law

Not all tax fraud in the UK results in a criminal investigation and prosecution. HMRC still have 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 this 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. A few thousand specially trained officers within the FIS Directorate work the individual cases. 'FIS' (pronounced 'FIZ')has nothing to do with champagne but stands for Fraud Investigation Service.

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