HMRC’s most serious civil investigation type, where tax fraud is alleged from the outset. COP 9 is usually commenced by HMRC but can be entered into voluntarily.

An outline disclosure needs to be made to HMRC within 60 days of the COP 9 enquiry commencing. This needs to contain as much detail as possible about all deliberate and non-deliberate tax irregularities and this document is of paramount importance as only irregularities disclosed here will be immune from criminal prosecution. Following this, an in-depth meeting will be held with HMRC to discuss the outline disclosure and in most cases a full disclosure report will be commissioned after this, in which all irregularities will need to be fully explained with supporting evidence and disclosed to HMRC.

Taking professional advice in relation to Code of Practice 9 is essential, given the fine margins which could lead to a criminal prosecution for an incomplete or incorrect disclosure. Our team includes a former HMRC Fraud Investigation Service (FIS) senior inspector who can offer unique insight into the process. We have a wealth of COP 9 experience, helping our clients achieve their main aim of avoiding criminal prosecution but also assisting in negotiating a more favourable settlement in terms of penalty rates and payment arrangements.

Our team are experienced in representing you and negotiating settlements with HMRC.

Settlements can cover a broad range of historic tax matters, most topical at the present time are those in respect of taxpayer investments which HMRC perceive to be tax avoidance schemes. These include but not limited to film partnership structures, offshore structures, disguised remuneration – ‘contractor loans’, EBTs, umbrella companies.

HMRC are focussed on attacking such investments through their counter-avoidance department and legal action through the courts. Such action is protracted, causing stress and worry for the taxpayers involved.

Settlement opportunities offer individuals an ‘out’ – a chance to enter into a mutual settlement with HMRC in order to provide finality. Normally this is in exchange for payment of tax due plus late payment interest.

Our approach – we will review all of the available information to advise the best course of action, with regards to your personal circumstances.

Our focus is you, we communicate direct with HMRC on your behalf and keep you fully to do date each step of the way. We understand settling with HMRC will impact on cashflow, payment arrangements form part of the settlement process.

Disputes with HMRC can take many forms including appeals, alternative dispute resolution (ADR), claims, disputes and ultimately Tribunal.

We appreciate how daunting a dispute with HMRC may feel, with an individual or a company going against an entire government department, however we also appreciate HMRC make mistakes and the importance of defending your position, and the potential financial costs of not doing so.

Where such a dispute arises, our experienced team are best placed to assist. We hold a detailed knowledge of HMRC’s powers, guidance and tax legislation, with a proven track record in successful arguments defending our clients’ positions.

Should a dispute need to be escalated to the next stage for any reason we can advise on the most effective way of doing so, communicate direct with HMRC and guide you with the process.

Our team are experienced in representing you and negotiating settlements with HMRC.

Settlements can cover a broad range of historic tax matters, most topical at the present time are those in respect of taxpayer investments which HMRC perceive to be tax avoidance schemes. These include but not limited to film partnership structures, offshore structures, disguised remuneration – ‘contractor loans’, EBTs, umbrella companies.

HMRC are focussed on attacking such investments through their counter-avoidance department and legal action through the courts. Such action is protracted, causing stress and worry for the taxpayers involved.

Settlement opportunities offer individuals an ‘out’ – a chance to enter into a mutual settlement with HMRC in order to provide finality. Normally this is in exchange for payment of tax due plus late payment interest.

Our approach – we will review all of the available information to advise the best course of action, with regards to your personal circumstances.

Our focus is you, we communicate direct with HMRC on your behalf and keep you fully to do date each step of the way. We understand settling with HMRC will impact on cashflow, payment arrangements form part of the settlement process.