HMRC COP 9

HM Revenue & Customs (HMRC) investigation of fraud statement The Commissioners of HMRC
reserve complete discretion to pursue a criminal investigation with a view to prosecution where they consider
it necessary and appropriate.

In cases where a criminal investigation is not started, the Commissioners may decide to investigate
using the Code of Practice 9 (COP9) investigation of fraud procedure.

Under the investigation of fraud procedure, the recipient of COP9 is given the opportunity
to make a complete and accurate disclosure of all their deliberate and non-deliberate conduct that has
led to irregularities in their tax affairs. Where HMRC suspects that the recipient has failed to make a full disclosure
of all irregularities, the Commissioners reserve the right to start a criminal investigation with a view to prosecution.

The term 'deliberate conduct' means that the recipient knew that an entry or entries included in a tax return
and/or accounts were wrong, but the recipient submitted it/them anyway, or that the recipient knew that a liability to tax existed but chose not to tell HMRC at the right time.

In the course of the COP9 investigation, if the recipient makes materially false or misleading statements,
or provides materially false documents, the Commissioners reserve the right to start a criminal investigation into that conduct as a separate criminal offence.