Code of Practice 9 (CoP9) Investigations

Have You Recieved a CoP9 from HMRC?

Find out what you need to do and what you need to know.

How We Can Help You

We can draw on over 100 years' combined experience to manage risks & ensure you obtain the best possible outcome.

What is CoP9?

CoP9 or, Code of Practice 9, is an investigation that is carried out by HMRC. This can happen in cases where they believe that someone may have committed tax evasion; usually when they notice or suspect a big loss of VAT or tax.

In most cases where a CoP9 has been issued, HMRC will carry out a criminal investigation to identify if there has been any fraudulent activity, with the view to prosecute. If you have received a CoP9, this is considered to be HMRC’s most serious civil investigation and it should not be ignored.

What Can I Do If I've Received a CoP9?

If you have been issued with a CoP9 from HMRC, the best thing to do is to deal with this as quickly as possible. When HMRC issue a CoP9, they will offer you the chance to to make a full disclosure under a Contractual Disclosure Facility (CDF), which can help you to avoid being criminally investigated.

What is a Contractual Disclosure Facility (CDF)?

A contractual disclosure facility (CDF) offers you the opportunity to let HMRC know of any deliberate activity that may have happened that has caused a loss of tax.

If you receive a CoP9 and you think that it is correct, then the best thing to do is accept a CDF, which will mean that HMRC will agree to not criminally investigate with a view to prosecute you, and both yourself and HMRC will come to some agreed terms and conditions.

How Long Do I Have to Accept a CDF?

Once you’ve received a CoP9 letter from HMRC, you will have 60 days after receiving this to decide whether or not to accept the offer of CDF.

Within this time HMRC can still take action against good you own, can start or continue debt collection, as well as any other action they deem necessary as part of HMRC's legal obligations. This is why it is best to act as soon as you can, if you receive a CoP9 letter, in order to try and resolve any issues.

What if I Don’t Accept the Offer of CDF?

If you think that the CoP9 is incorrect, you can choose to reject the CDF. If you do this you will be contacted by someone from HMRC to advise you on what the next steps will be. A rejection of CDF will most likely result in HMRC carrying out a criminal investigation into your tax affairs. If it is found that there has been conduct resulting in a loss of tax, the letter you have signed can be used in court as evidence to suggest that you have deliberately attempted to mislead HMRC.

How Can Pannu Tax Help?

If you have received a CoP9, it is recommended to get advice as soon as possible. Pannu Tax have over 100 years' combined experience in tax investigations, disputes, and enquiries. If you choose us as your tax advisors to help with your CoP9 investigation, you can rest assured that you will be advised by some of the UK’s leading tax investigation specialists.

Our tax advisors have the practical experience and technical knowledge required to provide you with the support you need during this time.

By choosing to work with Pannu Tax, whether it’s for advice on CoP9 or any other tax-related disputes, you will have access to the knowledge and experience of HMRC's procedures and processes - which can usually only be found in the UK’s top accountancy firms - at an affordable price.

Our Founder & Director, Ronnie Pannu, explaining the CoP9 process...

How can we help?

For a free, confidential and no obligation discussion call us on 0800 246 5915 or email us direct at

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Expertise & Experience

At Pannu Tax you will be advised by some the UK's leading tax investigations and dispute specialists who have the practical experience and the technical knowledge required to provide you with the type of effective support you need.

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