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Introduction

The vast majority of HMRC enquiries, or ‘checks’ as they are now more commonly called, are carried out by staff in the network of tax offices across the UK. A formal notice is issued and the individual, sole trader, partnership or limited company is told which tax return is to be the subject of a check. Typically, the HMRC officer requests information to conduct the check, in order to confirm the accuracy and completeness of the tax return in question.

However, HMRC also has specialist teams conducting civil and criminal investigations where it suspects serious tax fraud, involving direct and / or indirect taxes, has taken place. HMRC considers a tax fraud to involve an element of deliberate behaviour where, for example, there has been a failure to declare a tax liability, a concealment or withholding of information or a misrepresentation of facts.

HMRC’s regime for handling serious fraud cases is called the contractual disclosure facility (CDF). Code of Practice 9 (COP 9, also known as Code 9) governs how HMRC