|WAMS Tax Ltd
|COP9 & CDF
Enquiries - Serious
|SCI or CIF work needs
and careful preparation of your
or click below to
|Bill has the specialist skill to help if
you get a letter from SCI or one of
Contact Bill at the earliest point
to ensure matters are not
Time is critical and the clock is
ticking as soon as you sign for
that registered letter from
|Code of Practice 9 (COP9) Facility
You have to know what you are doing!!
Don't take the risk of inexperienced handling
|HMR&C Prosecutions -
While Prosecutions need to be handled by a legal team it is
clearly advantageous to have ex-HMR&C experience on the
team. Bill Stevenson is willing and able to competently help in
relation to the tax defence and provide advice to any legal team
involved. Check out this link to Prosecution Policy to see if
there is a risk of you being prosecuted.
Contact Bill on 07751720507 if you need to discuss a
COP9 letter (or even better obtaining the protection of
COP9 before HMRC come a knocking or offer it). In this
way you can also potentially avoid being published as a
deliberate defaulter or as Inspectors call it "named and
FRAUD INVESTIGATION SERVICE Office - COP9 :
If you have received a letter from the HMRC's FRAUD
Investigation Service - Fraud and Bespoke Avoidance
(Previously SCI or CIF or Inland Revenue Special Compliance
Office) then you really need to get specialist advice as
usually you have material problems to consider. I can
help you and first consultation free!!! Into the bargain in
the first 60 days from receipt of the letter you are on your
own if your adviser doesn't have the necessary
experience to guide you through an "outline disclosure"
or the precarious "rejection of the COP9 offer" from
Contractual Disclosure facility / CIF Team- Now called
Fraud Investigation Service - Get it sorted Bill I can help!!!
If you have received a letter from one of the HMRC's
Contractual Disclosure or Taxes Criminal teams (previously
dealt with by SCI and now the Fraud Investigation Service) then
you really need to get specialist advice as they are looking for
large amounts or may have incorrect information that needs
You can also still get prosecuted (see link here) if you do
not do things correctly but I can help you to ensure that
this doesn't happen!!!
The procedures changed from February 2012 and again from
2014 so make sure that your specialist is up to date with the
Contractual Disclosure Facility (CDF) as getting it wrong can
still lead to prosecution if you don't do things correctly.
You will also miss the CDF opportunity if HMRC do not have
your acceptable outline disclosure within 60 days of the date on
the CDF letter. A day late and HMRC can refuse to
entertain it as a disclosure - and DO do this - so you need
to be aware of the possible strategies early on.
I have the knowledge having been involved in the setting up of
these CIF teams for Scotland Wales & Northern Ireland. I also
have the specialist advice to help you ensure that you get the
best deal you can. There are a number of things that need to
be taken care of to ensure that you are not prejudiced.
While we can get the Gaurantee of No Prosecution we
must also deal with matters carefully so that the immunity
is not subsequently lost.
CIF stands for Civil Investigation of Fraud and FIS stands
for Fraud Investigation Service.
HM Revenue & Customs investigations into cases of suspected
serious tax fraud, tax evasion and tax avoidance have for many
years been dealt with by specialist offices. Special Civil
Investigation of fraud units are similar in set up to the old
Special Compliance Office, Enquiry Branch and Special Offices
set up in the 1970s and 1980s.
As more and more Inspectors are redeployed back to local
districts and staffing is "streamlined" it is likely that more CIFs
will be dealt with locally so taxpayers and their advisers need to
be alert to enquiries issued under Code of Practice 8 (COP8)
and Code of Practice 9 (2014) (COP9) but not from the usual
From around July 2006 CIF teams started operating in Local
Compliance led by team leaders with Ex- Enquiry
Branch/SCO/SCI experience, these teams are undertaking work
previously restricted to the Specialist Fraud Enquiry offices and
incorporating both Direct (IR) and Indirect(VAT) enquiries under
the one code. They deal with all tax irregularities whatever the
tax type IHT to Tax Credits, Direct tax to Indirect tax. Nothing is
Since 2015 both the prosecution and civil settlement arms of
HMR&C have been merged under the banner of Fraud
VAT Serious Non Compliance enquiries and also SOCA
investigators may be operating in close contact.
You need to make sure that you get it right first time as there is
not usually a second chance if you miss something material
Need help or even a second opinion call Bill on
07751720507. Having done it on the other side I know the
pitfalls and secrets of how far HMR&C can actually go.
Because it is so serious Bill does not put anything on
here that could be construed as advice as each case
needs to be seriously considered on its own merits BUT
generally it is believed that cooperation is the best way
of taking matters forward.
However remember you cannot put in Box 4A of the form
anything that does not constitute deliberate tax evasion
or tax fraud. So if you honestly believe that you have not
committed such "crimes" you should not sign the
acceptance certificate and therefore reject their offer -
leaving HMRC to all of a sudden have to decide whether
to consider an investigation with a view to prosecution
or an alternative strategy.
Avoidance Schemes -
If you have paid out loads of money on a tax avoidance scheme
don't accept that HMRC has approved it merely because your
seller said it had an HMRC registered number. This merely
means that HMRC are aware of the scheme and may well
challenge it in the near future. See the HMRC Spotlights
articles that let you know the ones they are challenging and
what they say about others.
An interesting recent development is HMRC using "COP9"
procedures to flesh out their anti-avoidance attack - be careful
as you can still get prosecuted for tax avoidance if you
provide false or misleading information and documents.
Such ill conceived attacks by HMRC (of issuing COP9 in
solely tax avoidance cases) need careful and robust
handling and knowledge of HMRC procedures to defend
Offshore Bank Account Project Team -
Be aware that Offshore income tax evasion carries heavier
penalties (up to twice) those of normal onshore/domestic tax
evasion. So you need expertise even more to reduce or even
hopefully negate penalties. These Teams are under instruction
from their national offshore bank account project team and
basically will try and circumvent the statute and limitations
imposed on them by the law. Don't let them bully you ....... but
also be aware of the Tax "amnesty" Campaigns that are on the
go from time to time see HMRC Tax Campaigns
Naming and shaming -
Doesn't sound good and it isn't if you are worried about your
name being publicised on the HMRC website for 12 months as a
serious tax evader. see Managing Serious Defaulters
where you can see the usual questions and answers as
publicised by HMRC.
However if you go forward voluntarily and before HMRC send
out their "invitation" letter you can also avoid such publicity by
fully cooperating and disclosing your tax irregularities.
Into the bargain it is inevitable that somebody going
forward BEFORE they are caught carries a lot more
credibility when it comes to negotiating and settling with
Also remember that HMRC might not on every occasion get it
right and therefore you need appropriate expertise (and
experience) to get the proper strategy for your situation.
Get Bill Stevenson's help in understanding their powers and
limitations and work your enquiry to best benefit. There are
always ways to save money and cover my reasonable fees.
Call me on 0775 1720507 at any time for an initial chat at no
charge or use the contact email. Please remember however I
pick my clients carefully so you need to be totally up front from
the start and trust me. Others already have and you can see
the results from their Testimonials.
Bill can help you in any COP9 enquiry
Phone 07751 720507
for an initial confidential chat