tax investigation
15 years’ Experienced team
tax investigation
We take control
tax investigation
On your side

COP9 & Tax Avoidance/Evasion Investigations

VAT Fraud Investigation

COP9 & Tax Avoidance/Evasion Investigations

If you have been advised that HMRC is starting a Code of Practice 9 investigation, then this is because they suspect a severe loss of tax. COP 9 investigations are serious, and HMRC strongly advises you to take professional and independent advice.

You will be asked to make a disclosure, and if this is managed poorly, this can lead to higher penalties and the possibility of a criminal investigation and prosecution. However, making a disclosure is admitting fraud, and the penalties are much higher than those for careless financial inaccuracies.

For these reasons, you should always seek the advice of a tax specialist.

What Is A COP9 Investigation?

A COP 9 investigation is a civil procedure instigated by HMRC when they suspect tax fraud, but decide not to initiate a criminal investigation. The taxpayer is offered the opportunity to make a full disclosure and admit to the fraud, in exchange for no criminal prosecution. This is called a Contractual Disclosure Facility (CDF), and you will have 60 days to respond and accept the offer.

The CDF requires you to offer full co-operation and accept penalties and interest, which will be given a more significant reduction if due. You can also avoid insolvency and publication of your name and other details.

Contractual Disclosure Facility

If you accept the CDF you must accurately disclose all non-deliberate and deliberate tax irregularities. Not making a full disclosure can result in the HMRC commissioners starting a criminal investigation. You must also cease all actions that may result in future tax losses. If you provide false documents or make misleading or false statements, a separate criminal investigation can be started as this is considered a new criminal offence.

If you deny the CDF, refuse to co-operate, and refuse to confirm the fraud, HMRC will start an investigation that may be a criminal investigation. HMRC can initiate legal proceedings to acquire some or all of your assets, charge significantly more significant penalties, and get information on your business affairs from third parties. HMRC can also raise an assessment of the tax and interest due and require financial security from you against the unpaid taxes.

COP9 Specialist Professional Representation

MS Taxes is a COP9 specialist and tax dispute specialist. We can help you decide if you should accept or deny the CDF offer and:

  • Review your tax affairs
  • Make you aware of the risks and issues you face
  • Present your disclosure to HMRC
  • Prepare a strategy to minimise your exposure to unnecessary penalties, tax, and interest
  • Resolve your COP9 investigation as quickly as possible with minimal disruption and cost to you

You will give HMRC authority to deal with us directly, and we will represent you, removing much of the stress you would otherwise encounter. Remember, if you do nothing, HMRC will continue with their investigation, and penalties could be higher.

Contact Our Team

Get in touch with us for confidential and no-obligation tax advice.

Call us on:
0333 577 6909

Email us at:

What to expect from our team...

  • HMRCPenalty Appeals & Tax Hearings

  • HMRC Tax Investigations

  • VAT Specialist Advice & Investigation

  • Contractual Disclosures

  • Offshore Disclosures

  • Voluntary Disclosures

Here to help, not to judge
Tax Specialist


Partner Nicola has a wealth of experience in dealing with all types of Indirect Tax Investigations (VAT).
Nicola has been VAT Inspector for over 20 years at HM Customs now HM Revenue & Customs. She was a Higher Officer for more than 10 years.
Her duties included carrying out vat inspections of all types and size of businesses dealing with technical issues to detecting evasion. Nicola recently joined MS Taxes as head of Indirect Tax Investigation.

Contact Tofail Rahman on:

Tax Investigation Specialist
Tofail,Founding Partner and Tax Investigation Specialist


Founding Partner

Tofail is a qualified Chartered Accountant with over 15 years of experience in accountancy and taxation.
He has worked alongside a former Inspector of Taxes gaining invaluable insights of inner HMRC workings, which he utilises to support clients through tax challenges and steer clear from possible investigations.
Contact Tofail Rahman on:

Tax Specialist
Tim,Founding Partner


Founding Partner

Tim has a wealth of experience dealing with all types of International Payroll Tax and IR35 Tax Investigations.
Tim has worked within Financial Services and Accounting since 2001 including working with HMRC on VAT investigations.
He is a specialist in International Taxation Experience, International PEO Employment Solutions as well as in providing solutions for contractors and limited companies.

Contact Tofail Rahman on:

Worldwide Disclosure Expert



Andrew began his career in HM Customs & Excise and subsequently moved to HMRC (then called the Inland Revenue) on appointment as one of HM Inspector of Taxes.
completing his training he was sent as District Inspector in charge of West Midlands and was soon transferred to Head Office as a fraud investigator in Enquiry Branch (now Fraud Investigation Services) where he spent eight years conducting Code of Practice 9 investigations on a wide variety of individuals, partnerships and companies.

Contact Tofail Rahman on: