Our approach

Serious tax investigations are dealt with by HMRC’s Fraud Investigation Service (FIS). These are extensively trained and often more experienced individuals who are tasked with investigating cases where there is either a suspicion of tax loss through an individual’s deliberate acts or omissions, or a belief that too little tax has been paid but fraud is not suspected.

HMRC receive vast amounts of information and data from third parties both within and outside of the UK, which has led to an increase in the number of serious tax investigations. Menzies experts are vastly experienced in guiding clients through all serious tax investigations and disclosures. We can help clients achieve the best possible outcome and have a track record of doing just that. It is always better to be proactive and, under expert guidance, approach HMRC before waiting to be approached by them whenever possible.

You do not need to wait for HMRC to start investigating, and by following Menzies’ advice you will receive the greatest protection. We strongly encourage you to contact us without delay.

Code of Practice 9 COP9

Cases are dealt with under COP9 where HMRC either suspect, or the individual voluntarily discloses, that their deliberate action or inaction has led to an insufficient amount of tax being paid. HMRC refer to such behaviour as “tax fraud” but this is more commonly known as tax evasion. Code of Practice 9 cases are processed through HMRC’s Contractual Disclosure Facility (CDF) and taxpayers will either be issued with COP9 by HMRC, or can choose to voluntarily use the facility.

The principal benefit of COP9 for taxpayers is provided a full disclosure is made then HMRC will guarantee immunity from criminal prosecution.

There is a formal process to follow with strict deadlines to meet so assistance from an experienced Tax Disputes advisor is highly recommended, and it is better to appoint a COP9 specialist advisor such as Menzies at the earliest opportunity.

Code of Practice 8 COP8

Cases dealt with under COP8 are those where HMRC suspect there has been an insufficient amount of tax paid, but “fraudulent behaviour” is not suspected. HMRC investigations into tax avoidance arrangements or where there is a potential risk of significant tax loss are typically dealt with under COP8.

If you require advice on either COP9 or COP8, we strongly recommend you call us immediately for a free and confidential discussion.

Understanding HMRCs Code of Practice 9 (COP9)