Contractual disclosure facility (CDF) ― the role of the agent

Copyright © 2025 LexisNexis
Produced by Tolley in association with Guy Smith of Independent Tax
Owner-Managed Businesses
Guidance

Contractual disclosure facility (CDF) ― the role of the agent

Copyright © 2025 LexisNexis
Produced by Tolley in association with Guy Smith of Independent Tax
Owner-Managed Businesses
Guidance
imgtext

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, then 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

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Guy Smith
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Senior Manager, Independent Tax

Guy joined Independent Tax in November 2022, returning to his roots handling tax investigations, disclosures and all manner of other HMRC tax disputes, on behalf of the firm’s clients. His remit also includes mentoring junior colleagues and managing the firm’s social media content and marketing output.Guy’s previous roles have included 15 years at HMRC and a similar length of time at Markel Tax, where he managed the team of Senior Tax Consultants, alongside delivering live presentations and webinars to accountants.Guy has been a consultant editor and writer for Tolley Guidance since July 2012 and a member of the ICAS Technical Bulletin editorial board since May 2014.

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  • 20 Jul 2023 10:46

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