Introduction

HMRC’s regime for handling serious fraud cases is called the contractual disclosure facility (CDF). Code of Practice 9 (COP 9, also known as Code 9) governs how HMRC investigates suspected fraud and sets out the rules and conditions of the CDF policy.

It is recommended you read the Contractual disclosure facility (CDF) guidance note to familiarise yourself with the regime.

This guidance note discusses the role of the agent in assisting the individual who is offered the opportunity to participate in the CDF and is sent a copy of COP 9.

If a form 64-8 or form COMP1 is registered with HMRC, the agent will receive a copy of the opening letter sent by HMRC to their client.

Where does the agent start?

It may seem obvious, but the first step is to record the date the opening letter, containing the CDF offer and a copy of COP 9, is received. The client only has 60 days from receiving the offer to make a