This tax investigation case came to us from a high net worth individual who was being investigated by HMRC under a Code of Practice 9 (COP 9). Before approaching us, the client’s Code of Practice 9 (COP 9) investigation was being handled by a well reputed firm who had been handling the case from the onset and had made the initial outline disclosure under the Contractual Disclosure Facility (CDF). As the Code of Practice (COP 9) investigation had been ongoing for several years and the client felt that they were not getting the expected results, he approached our team of tax investigation specialists.
After our initial meeting with the client, our team of tax investigation consultants was quickly able to route the weaknesses in the approach previously taken. Our team of tax investigation experts established close contact with HMRC’s Code of Practice 9 (COP 9) unit from the point of our appointment and used their experience and expertise to discuss and agree all aspects of our client’s full disclosure with HMRC. Using this approach, when we submitted the final disclosure under the Contractual Disclosure Facility (CDF), it was accepted by HMRC with limited queries and adjustment. The final tax liability was much lower than when we initially took on the case.
Handling tax enquiries under Code of Practice 9 (COP9) requires specialist knowledge and experience and have to be dealt with care and caution. There is always a risk of prosecution if HMRC are not satisfied with the disclosure being put in front of them. At Churchill Tax Advisers, our team of tax investigation specialists has expert knowledge and years of experience in dealing with Code of Practice 9 (COP 9) investigations. If you have received a letter from HMRC and are being investigated under Code of Practice 9 (COP 9), please feel free to contact us for a free and confidential consultation.