Code of Practice 9 (COP9) Investigations
Experts in COP9 Investigations – When HMRC Possesses Proof of Tax Evasion

A Code of Practice 9 (COP9) Investigation is one of the most serious forms of tax enquiry that HM Revenue & Customs (HMRC) can initiate. It is not a routine compliance check — it represents the highest level of civil investigation undertaken by HMRC’s Fraud Investigation Service (FIS) when they suspect, or possess evidence of, deliberate tax evasion.

If you have received a COP9 letter, it means HMRC believes that serious tax fraud or deliberate dishonesty has occurred, although criminal prosecution has not yet been pursued. Instead, HMRC offers the taxpayer the opportunity to make a full and honest disclosure through the Contractual Disclosure Facility (CDF).

This is your chance to avoid criminal proceedings by cooperating and disclosing all deliberate errors, omissions, and irregularities in your tax affairs.

Understanding a COP9 Investigation

HMRC’s Code of Practice 9 framework is designed to investigate cases where deliberate tax evasion or fraud is suspected. The investigation may cover a wide range of taxes and extend back up to 20 years, including:

  • Income Tax

  • Corporation Tax

  • VAT

  • Capital Gains Tax

  • PAYE and NIC

  • Inheritance Tax

  • Offshore income and assets

The process typically begins with a COP9 Investigation letter from HMRC’s Fraud Investigation Service. This correspondence formally invites the taxpayer to participate in the Contractual Disclosure Facility (CDF), offering a civil route to resolution rather than a criminal one.

It is critical to understand that a COP9 letter is not speculative — HMRC only issues it when they already possess or have gathered substantial evidence suggesting deliberate tax evasion.

What the Contractual Disclosure Facility (CDF) Means

The Contractual Disclosure Facility gives taxpayers a single opportunity to disclose all deliberate irregularities in exchange for immunity from criminal prosecution. To take advantage of this facility, the taxpayer must:

  1. Accept the offer – by signing and returning the acceptance letter within 60 days of receiving the COP9 letter.

  2. Provide a full disclosure – including a complete outline of all deliberate and careless errors in their tax affairs.

  3. Submit a full disclosure report – a detailed document outlining the nature of the irregularities, how they occurred, and the amount of tax involved.

Failure to respond within the 60-day window, or failure to make a full and truthful disclosure, may lead HMRC to withdraw the civil settlement option and consider criminal prosecution instead.

Our Expertise in COP9 and Serious Tax Investigations

At Holland & Co Chartered Accountants, we specialise in representing clients under COP8, COP9, and other serious HMRC investigations. Our team combines technical tax expertise with strategic experience to manage every stage of the process with precision, professionalism, and discretion.

We have successfully assisted clients in making voluntary disclosures, negotiating settlements, and avoiding prosecution through full compliance with the COP9 framework.

Our services include:

  • Initial assessment of your COP9 letter and its implications.

  • Strategic guidance on whether to accept the CDF offer.

  • Preparation of your disclosure report, including analysis of income, assets, and historic tax records (covering up to 20 years if required).

  • Negotiation with HMRC on penalties, settlement amounts, and payment terms.

  • Representation and correspondence – acting as your professional liaison with HMRC throughout the investigation.

  • Post-settlement advice – ensuring your ongoing compliance and helping to restore your financial and professional standing.

We also assist clients facing related allegations under the Money Laundering Regulations (MLR), ensuring all disclosure procedures are handled lawfully and in your best interests.

What You Should and Should Not Do

When faced with a COP9 investigation, your actions in the early stages are crucial.

Do:

  • Contact a professional adviser immediately — do not respond to HMRC without expert representation.

  • Cooperate fully once you have professional guidance in place.

  • Keep all correspondence, financial records, and evidence organised.

  • Be completely transparent when preparing your disclosure report.

Do Not:

  • Ignore the COP9 letter or delay your response — this may lead to criminal action.

  • Attempt to handle the case yourself — HMRC’s Fraud Investigation Service operates under strict legal protocols.

  • Destroy or conceal evidence — doing so could constitute a criminal offence.

Why Choose Holland & Co for COP9 Representation

A COP9 investigation is a serious matter that requires immediate and expert attention. With over 39 years of experience advising clients on complex tax and compliance issues, Holland & Co provides a calm, structured, and effective approach to resolving disputes with HMRC.

We act swiftly to protect your interests, minimise financial exposure, and preserve your legal rights. Our deep understanding of HMRC’s investigation procedures allows us to navigate the process efficiently, ensuring that every disclosure is comprehensive and accurate.

We also maintain strict confidentiality at every stage and liaise directly with HMRC on your behalf, sparing you the stress and uncertainty of direct communication.

Next Steps

If you have received a COP9 letter or believe that HMRC may be investigating your tax affairs, it is essential to act immediately. Early professional advice can make a significant difference to both the outcome and potential penalties.

Contact us today for a confidential consultation with our specialist tax investigation team. We will review your circumstances, explain your options under the Contractual Disclosure Facility, and provide the expert guidance needed to achieve a fair and compliant resolution.

For further information, please see our FAQ section on COP9 Investigations, which provides detailed answers to the most common questions about HMRC’s procedures, timeframes, and disclosure requirements.