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COP 9: policy and practice

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COP 9 is an established civil investigation procedure issued in cases where HMRC suspects tax fraud. The present COP 9 contains an optional contractual disclosure facility (CDF) which HMRC offers to all COP 9 recipients at the start of the COP 9 investigation. However, only those who are prepared to be bound by the conditions and accept the offer within the 60-day time limit will be given certainty that HMRC will not commence a criminal investigation into the tax fraud disclosed in outline. An effectively worked COP 9 case requires careful management of client and HMRC expectations, whilst ensuring the legality of the investigation using the safeguards built into the formal assessing and information gathering powers. Balancing control of scope and satisfactorily addressing reasonably held risks can be safely negotiated within the COP 9 framework.

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