HMRC Investigations: Code Of Practice 9

Not all tax fraud results in a criminal investigation and prosecution. HMRC 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). 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.

Most COP9 cases are started by HMRC but a taxpayer who wishes to make a voluntary disclosure is usually received with a welcome. The procedure is the same and the financial penalties are usually lower. The modern practice is for HMRC to offer a contract to the taxpayer to participate in its Contractual Disclosure Facility (CDF) whereby in return for a full disclosure of all deliberate tax fraud, continuing cooperation throughout the enquiry and payment of tax