Description
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Investigations into suspected serious tax fraud are typically conducted using the civil procedures outlined in Code of Practice 9. If you are under investigation using this method, HMRC will promptly inform you. They will provide you with a copy of the Code of Practice to underline the gravity of their concerns and invite you to disclose information under the Contractual Disclosure Facility. Usually, HMRC's suspicions are supported by substantial evidence, as they conduct extensive research before formally initiating the investigation under Code of Practice 9.
A tax investigation initiated by a local compliance tax office can be elevated to a tax fraud or tax evasion investigation under Code of Practice 9 if the local compliance office inspector uncovers evidence of more serious misconduct during their inquiry. In such cases, the local office inspector will refer the case to HMRC’s Fraud Investigation Service team.
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How Code of Practice 9 Works
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Under the Contractual Disclosure Facility procedures outlined in Code of Practice 9, the taxpayer is required to make a full disclosure to HMRC regarding any errors or omissions in their tax affairs, potentially spanning the previous 20 years. The taxpayer must discuss these matters with their tax adviser to prepare a comprehensive report for HMRC, disclosing any previous errors or omissions and providing evidence to support the disclosures made.
If the taxpayer makes a full and complete disclosure to HMRC, cases of tax fraud or tax evasion can be resolved within the civil arena, without resorting to criminal prosecution. However, if the disclosure made is inadequate, HMRC retains the option to pursue criminal charges.
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How We Can Help
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HMRC regards these cases as highly serious, with potentially damaging consequences for the taxpayer. Most accountancy practices have limited experience dealing with such cases. Therefore, it is imperative that the taxpayer seeks specialist advice from a suitably qualified and experienced tax investigations practitioner to ensure matters are handled appropriately.
If HMRC has contacted you regarding suspected tax fraud or tax evasion, or if you suspect you may have committed such offenses, our specialist tax team can represent you to expedite the investigation's resolution.
We will meet with you initially to discuss the situation and devise a strategy for engaging with HMRC.
We aim to alleviate the stress associated with a tax investigation by managing interactions with HMRC on your behalf. This means you are unlikely to have to meet or speak directly with a tax inspector during the investigation.
Throughout our work, we will seek to minimize your tax liability while ensuring you make a full disclosure to avoid criminal prosecution or public exposure.
If you have committed tax fraud or tax evasion and have not yet been challenged by HMRC, and you wish to voluntarily rectify your tax affairs, our dedicated team can make a managed voluntary tax disclosure to HMRC on your behalf. By doing so, we can secure immunity from prosecution.
If you are facing allegations of tax fraud or tax evasion, please contact us for a free, confidential, and no-obligation discussion. We are happy to offer an initial meeting free of charge to prospective clients.