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 contractual disclosure facility (CDF) issued to the taxpayer at the start of the investigation that the taxpayer can use to admit fraud to HMRC. For details of the opening of a COP 9 investigation and whether the taxpayer might be the subject of an unannounced visit by HMRC in advance of this, see A7.423.
For details of the investigation that may be started into tax avoidance where fraud is not suspected, see A7.422.
What is the contractual disclosure facility (CDF)?
The CDF is a contract between the taxpayer and HMRC. It allows the taxpayer to admit to fraud and make a disclosure of all arrears.
HMRC will not give a guarantee at the outset of an investigation under COP 9 that a taxpayer will not be investigated criminally. However, if the taxpayer
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 16:21