HMRC can issue a Code of Practice 9 enquiry for serious cases where they suspect deliberate or fraudulent behaviour has arisen to evade tax.
HMRC encourages recipients of a COP9 enquiry to admit their deliberate behaviour and participate in the Contractual Disclosure Facility (CDF) in order to resolve and settle the irregularities.
The COP9 enquiry process can be quite involved and involve significant risk. Typically, HMRC will want to meet with you in person and have a full report prepared. We can help you through every stage from initial notification to settlement.
From the date of notification you are under COP9 enquiry, there is an initial 60-day deadline to accept the invitation to participate in the CDF and provide an outline summary of the disclosure. A lot of work therefore needs to be done before you respond. Morley Tax has many years’ experience helping clients with COP9 enquiries.
Code of Practice 8 (COP8) investigations are issued by HMRC in cases where they suspect irregularities have arisen other than as a result of deliberate behaviour such as through tax avoidance arrangements.
If you have received either a COP9 or COP8 enquiry letter from HMRC it is recommended that you seek advice at the earliest stage from an experienced tax specialist.
- COP9 is used for serious tax fraud, often resolved via the Contractual Disclosure Facility
- COP8 covers complicated tax avoidance structures
Our Commitment
– We act fast and effectively
– We know HMRC’s procedures inside and out
– We’ve handled major cases for individuals and businesses alike



