COP 9 investigations

With the exception of criminal prosecutions, COP 9 investigations are the most serious type of HM Revenue & Customs (HMRC) enquiries.

COP 9 investigations – which can cover corporation tax, income tax, capital gains tax, PAYE and VAT – typically occur when HMRC believes it has strong evidence of under-declared tax but will choose not prosecute if the taxpayer co-operates with its investigation. Such cases take place when HMRC anticipates that the yield of tax, interest and penalties will be a minimum of £75,000.

Taxation-Investigation in Birmingham is experienced in COP 9 investigations and can help to minimise the stress of such an enquiry and the level of penalties, which can be up to 200 per cent of the underpaid tax where offshore tax issues are involved.

Co-operating with HMRC in a COP 9 investigation requires full disclosure of the tax matters that have triggered the investigation and a convincing argument on any tax issues if no irregularity has been disclosed. If HMRC believes an incomplete disclosure has been made, prosecution remains a possibility. The report must contain information to support the case you are putting forward and be prepared to a strict timeframe, which can be challenging if matters covered go back a number of years.

Taxation-Investigation’s expert team can help you to prepare a clear, comprehensive and convincing disclosure report that will assist in bringing the investigation to a swift conclusion and to maximise discounts on penalties, as well as advising and representing you throughout the enquiry. If the matter goes further, we can also provide specialist tax litigation support. Our services include:

  • advising on and preparing voluntary disclosure reports under COP 9
  • advising on and resolving COP 9 tax investigations
  • negotiating tax penalties or other elements of tax investigations
  • making a voluntary disclosure under the Liechtenstein Disclosure Facility.

To find out more about our tax investigation services in Edgbaston, Birmingham please contact Taxation-Investigation.