HM Revenue and Customs may issue a COP 9 notice if they suspect a taxpayer of serious tax fraud. These investigations are generally opened if HM Revenue and Customs expect to recover taxes in excess of £75,000 and they are able to go back as far as 20 years to identify unpaid tax.
Under COP 9 procedures, individuals are given immunity from prosecution if they provide full and complete disclosure of all irregularities in their personal tax affairs via the Contractual Disclosure Facility. This is a formal procedure that must meet specified criteria.
An investigation can be carried out under COP 8 in all cases involving possible serious tax fraud or avoidance where the procedures in COP 9 are not used. HM Revenue and Customs do not generally use the COP 8 procedure if they are considering a criminal investigation, however, if evidence of suspected serious fraud is found during their investigations then they may take action under COP 9 or commence criminal proceedings.
If a taxpayer is in receipt of either a COP 8 or a COP 9 notice then they should seek professional assistance as a matter of urgency to ensure that any formal procedures are followed and appropriate representations are made.
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