Contractual disclosure facility (COP9)

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The Contractual Disclosure Facility (CDF) is used by HMRC for cases of suspected serious tax fraud using the Code of Practice 9 (COP 9) investigation of fraud procedure. In such cases, HMRC will write to taxpayers inviting them to make a disclosure by way of a contract.

Providing a full and complete disclosure is made within agreed time limits, a civil settlement will be reached and the person will not be subject to criminal prosecution.

The CDF can also be used by taxpayers to make voluntary disclosures, before an approach by HMRC.

If you receive a letter from HMRC under the CDF, you only have 60 days in which to make an outline disclosure so we recommend you seek professional advice immediately. We can help you in identifying what HMRC may think is wrong about your tax affairs and then work with you to make the appropriate disclosures.

Or if you wish to make a full disclosure of any tax irregularities over the past 20 years this is an ideal way to do so ad guarantee yourself no prosecution.

For more information, please contact our Tax Investigations expert Lindsay Henson.

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