Where HMRC suspects that fraud has occurred it may commence an investigation into the taxpayer under Code of Practice 9 (COP 9 or Code 9). For an overview of COP 9 investigations, see A7.423. The commentary below considers the opening of such an investigation and whether the taxpayer might be the subject of an unannounced visit by HMRC in advance of this.
For details of the investigation that may be started into tax avoidance where fraud is not suspected, see A7.422.
Unannounced inspections prior to opening a COP 9 investigation
In exceptional cases, a Fraud Investigation Services (FIS) team may make an unannounced advance visit to the taxpayer to secure relevant documents as evidence which HMRC fear may be otherwise lost once the taxpayer has been notified of the COP 9 investigation1.
There must be clear evidence for the need for such action and it must be authorised by the FIS team's Operational Leader and the Authorised Officer. The case should have already been considered for criminal action and agreement
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