We settle and solve HMRC COP9 cases
The arrival of any unwanted brown envelope from HMRC is never a welcome experience for the taxpayer. We understand that the allegation of tax fraud at the initiation of a Code of Practice 9 inquiry can be alarming and threatening. We provide expert advice to ensure an efficient and cost-effective resolution.
Code of Practice 9 Defence
CODE of Practice 9 (COP9) is a procedure used by HM Revenue and Customs for investigating suspected serious tax fraud. It is part of HMRC’s civil investigation procedures and is designed to encourage individuals or businesses suspected of serious tax evasion to come forward and disclose their irregularities voluntarily.
Under COP9, HMRC offers individuals or businesses the opportunity to make a full disclosure of all irregularities in their tax affairs in exchange for reduced penalties and potential immunity from criminal prosecution. The process involves the taxpayer entering into a contractual agreement known as a Contractual Disclosure Facility (CDF), where they agree to cooperate fully with HMRC’s investigation and disclose all relevant information about their tax affairs.
If HMRC accepts the disclosure made under COP9, the taxpayer will typically be required to pay the outstanding tax liabilities, interest, and penalties. However, the penalties are often lower than those imposed if HMRC discovers the irregularities through its own investigation without the taxpayer’s voluntary disclosure.
It is essential that taxpayers seek prudent and forensic advice at the earliest possible opportunity. This can and does reduce penalties and/or the quantum of the purported tax liability, as well as ensuring calm after the storm.
Our solutions
We ensure businesses can continue to benefit from the flexibility and cost-effectiveness of limited company contractors in a compliant and coherent way.
Legal and Tax Compliance
Wolf’s approach to risk management absorbs all of the administrative costs of utilising limited company contractors and maintaining best-in-class legal compliance. Our solution ensures business can recover post-pandemic, and insures medium and large business against unnecessary risk from tax liabilities that ought not to vest in the limited company contractor’s end-client.
The COP9 Defence Team
Michael Paulin
Michael is a leading tax and employment barrister who specialises in IR35, corporate tax, and HMRC dispute resolution.
Michael has particular experience of corporate tax strategy as well as structured and long-term approaches to novel legal risks.
He is a member of Her Majesty’s Attorney General’s Panel of Counsel.
“Michael has the ability to soothe clients both through his delivery and how he presents the way forward” (Chambers and Partners, 2020).
Nicholas Gilbey
Nicholas has over twenty-five years experience in the industry. Nic has worked for blue chip companies like UBS and Thomson Reuters. He has run his own agency for over fifteen years and has worked as a consultant with clients like BP, Network Rail and Total.