We were contacted by a client from London who had several business interests and was being investigated by HMRC for several years. Initially, HMRC had started a routine compliance check but it was escalated to a Code of Practice 9 enquiry when the client contacted us. This normally happens if the compliance check is not handled carefully by a tax specialist and HMRC feel that the client is not fully cooperating.
Our team of tax investigation specialists had an initial meeting with the client to fully understand the case, the client’s background and his business interests. We then carefully prepared an initial outline disclosure which was accepted by HMRC and the client was allowed to make a full disclosure under Contractual Disclosure Facility (CDF) within a set time frame. Through careful planning and establishing a good contact with HMRC from early stage, we were able prepare and submit a disclosure which was accepted by HMRC and the final tax liability was much lower than what our client had anticipated. More importantly, through our experience in Code of Practice 9 investigations, we were able to ensure that the case was treated as a civil matter from the onset which reduces the risk of prosecution for our client.
In our experience, enquiries under Code of Practice 9 (COP 9) or Contractual Disclosure Facility have to be handled with extreme care and caution. The client can be prosecuted by HMRC if they are not satisfied with the information being provided to them. Our team of tax investigation specialist have extensive experience and knowledge of dealing with Code of Practice 9 enquiries or Contractual Disclosure Facility. Please feel free to contact us for a free consultation if you have received a letter from HMRC and are under a Code of Practice 9 tax investigation.