Fraud civil investigation - COP9 offers made with effect from 30 June 2014 - the disclosure

By Tolley
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The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Fraud civil investigation - COP9 offers made with effect from 30 June 2014 - the disclosure
  • Disclosure process

This guidance note provides an overview of the process that needs to be followed by a taxpayer who has accepted an COP9 offer from the 30 June onwards and they need to submit a disclosure to HMRC. This note should be read in conjunction with the Fraud civil investigation - COP9 offer made from 30 June 2014 - overview, Fraud civil investigation - COP9 offer made from 30 June 2014 - Initial meeting and Fraud civil investigation - COP9 offers made from 30 June 2014 - closing the case guidance notes.

Disclosure process

HMRC’s aim with the COP9 procedure is to ensure that the taxpayer makes a full disclosure and pays the correct amount of tax due for any fraudulent and non-fraudulent tax losses that have occurred.

Outline Disclosure acceptable

When the taxpayer submits the Outline Disclosure it will be reviewed by HMRC to ascertain whether it discloses the fraud that HMRC suspects has been committed. If HMRC is satisfied that the Outline Disclosure contains all of the relevant information and the fraud is straightforward, and as a result it will be easy to calculate the tax loss, it may not be necessary for a meeting with the taxpayer and / or their representative to be organised. In these circumstances HMRC will need the taxpayer to complete and return the following documentation and arrange payment of the amount to HMRC in order for the investigation to be concluded:

  • statement of assets and liabilities
  • certificate of bank accounts operated
  • certificate of debit and credit cards operated
  • certificate of Full Disclosure
  • arrange for payment to be made of the amount due to HMRC

Sample copies of some of these forms can be found in the

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