HMRC like their acronyms — Code of Practice 9 (COP9), FIS (Fraud Investigation Service), and CDF (Contractual Disclosure Facility) — all to be taken seriously, as they relate directly to HMRC tax fraud and potential criminal outcomes.

Whether you’ve received a COP9 letter or want guidance on a COP9 investigation, I provide immediate, expert support backed by years of HMRC experience.

Code of Practice 9 (COP9) investigations are the most serious type of civil investigation undertaken by HMRC and are conducted by the Fraud Investigation Service (FIS). HMRC FIS officers are experienced, highly trained, specialist fraud-trained investigators and should be taken very seriously. This is one of the most serious types of HMRC COP9 cases and should be handled with the utmost care.

COP9 investigations are only opened where HMRC suspects a loss of any tax or other duty through deliberate and fraudulent activity. For this reason, the initial letter from HMRC opens with “HMRC have information that gives us reason to suspect that you have committed tax fraud.” These cases are always handled by HMRC FIS specialists, and expert representation is crucial if you’ve received an HMRC FIS letter or notification of a fraud compliance check.

When HMRC FIS issues a COP9 investigation, it provides you with a one-time offer, known as the Contractual Disclosure Facility (CDF), whereby you will receive immunity from criminal investigation and/or prosecution in return for:

• Admitting you have acted deliberately in failing to declare income, gains, or duties; and
• Agreeing to fully disclose all omissions and irregularities that have arisen in the last 20 years

HMRC FIS investigations often lead to tax fraud penalties and significant stress for individuals and businesses. The right FIS defence can limit exposure and help negotiate outcomes before prosecution occurs.

By accepting HMRC’s CDF offer, you are also agreeing to pay penalty charges in addition to the interest that has accrued over up to 20 years.

Lindsay is a COP9 specialist.

FAQ – How long do I have to respond to a COP9 letter?

• You have 60 days to respond to HMRC’s CDF offer — failing to respond may increase your risk of prosecution.

Do not delay, from the date of receipt of HMRC’s COP9 CDF offer, you have 60 days to accept or reject it. This decision is vital to the outcome of the case and the financial, business and family impact on you.

Any COP9 investigation into your tax affairs will be time consuming and likely to be highly disruptive to your business and family life, but it can also be expensive in terms of tax etc and professional fees.

Here Lindsay’s involvement pays dividends, as not only will she give you a free initial overview on the phone, but her prices are more than competitive, for someone with over 40 years’ experience, both inside HMRC as a Tax Inspector and on the other side, the kind side helping you!

Her mantra is ‘everyone deserves a defence’ and she never gives up and with your help, this can be navigated in a way that you understand, accept, and can agree in the quickest possible time frame. She speaks your language and that of HMRC, in order to mediate and avoid unnecessary delays and stress for you.

It essential that you get expert, specialist advice from the very minute that you receive the letter, and a phone call is the best way – with ‘nothing ventured, nothing gained’ you will find Lindsay very approachable, practical, knowledgeable, helpful, and never judgemental. Whatever you decide you will go forward with more information, peace of mind and ‘forewarned is always forearmed’ and everything is in complete confidence.

What Is HMRC FIS?

The HMRC Fraud Investigation Service (FIS) is the most serious division within HMRC, focused on tax fraud, evasion, and criminal activity. If you’re facing an HMRC FIS investigation, early action and expert advice are essential to protect your rights and minimise penalties.

Voluntary COP9. It is also possible to come forward and ask to join the COP9 process on a voluntary basis. Here you complete a form and ask HMRC to offer you the chance to join this process. It will follow the same lines but will give you a much lower penalty for a voluntarily coming forward. Once accepted onto this your specialist advisor will complete your full disclosure of all irregularities and work with HMRC to agree the tax payable. This voluntary disclosure gives you immunity from prosecution as well as reduced penalty charges. Voluntary disclosure under the HMRC Code of Practice 9 route can reduce penalties and avoid prosecution.

Received a COP9 letter? Perhaps you need COP9 guidance or worried about a Code 9 HMRC investigation? Act now before deadlines pass. Call Lindsay today for confidential advice on 07879 464 577 at any time, but often a quick text, or contact me via email to book calendar time this ensures we both have time to devote to hearing your story and fears.

Please also see the Contractual Disclosure Facility service.