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HMRC has a selective criminal prosecution policy and may choose to conduct a civil investigation into a tax fraud, under Code of Practice 9 (COP9).
However, where HMRC needs to send a strong deterrent, they will conduct their investigation along criminal lines.
Examples of the kind of circumstances in which HMRC will generally consider commencing a criminal rather than a civil investigation are:
When considering whether a case should be investigated under Code of Practice 9 (COP9) procedures or is the subject of a criminal investigation, certain factors to be considered are whether an individual has made a complete and unprompted disclosure of the offences committed or not responded to the offer of the Contractual Disclosure Facility (CDF).
For more information and to arrange a free initial consultation please contact Doug Sinclair.