Code of Practice 9 cases


Andy Wood

Andy is a practical, creative tax adviser who assists a variety of clients in achieving their personal and commercial objectives in the most tax efficient manner.

Code of Practice 9 cases

What is COP9?

Code of Practice 9 (“COP9”) is a document that is issued by HMRC. It is part of its Contractual Disclosure Facility or CDF.

COP9 is only used by HMRC’s Fraud Investigation Service or FIS.

It should be noted that one may only use the CDF Facility where HMRC suspects serious tax evasion has taken place. This means that COP9 may only be used in the same scenario.

The COP9 letter will set out HMRC’s investigative process into the serious tax evasion that it believes has taken place.

Code of Practice 9 cases

A COP9 case should be established through a high degree of information obtained by HMRC.

One should not underestimate the vast amount of information that HMRC has at its finger-tips. We are in an unprecedented level of data and co-operation between international revenue authorities.

That said, data is only as reliable as those handling and reviewing the data.

Further, this information may not present the full and complete picture. An investigation from HMRC may then be built on unsteady foundations and professional management of the COP9 case should hopefully assist in bringing this out in to the open sooner rather than later

It should be stressed that HMRC only issue Code of Practice 9 where they believe that there is serious tax fraud (both in terms of the offence and the amount). However, those beliefs may be built on unreliable evidence.

We recommend that anyone who receives a COP9 letter to engage with a professional adviser as soon as possible.


Code of Practice 9 sets out the rules of engagement where HMRC suspects a taxpayer has committed what amounts to serious tax fraud.

By definition, COP9 cases are of a very serious nature. As such, one should not bury one’s head in the sand.

For further information regarding COP9 please visit our COP9 Signpost article here.

If you or your client have received a COP9 letter from HMRC, or have any queries about COP9 at all, then please do get in touch.

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