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. For commentary on 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, see A7.425. The commentary below considers the formal disclosure report that may be required under the CDF.
For details of the investigation that may be started into tax avoidance where fraud is not suspected, see A7.422.
Progression of the investigation where the contractual disclosure facility (CDF) is rejected or an incomplete or invalid outline disclosure is made
Where there is a rejection of the CDF or and invalid or incomplete outline disclosure (see A7.425), the investigation will either be further progressed on a civil basis under COP 9 or as a criminal investigation with a view to criminal prosecution1. See A7.430.
Usually, the taxpayer will be invited
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