HMRC’s revised Code of Practice 9

HMRC’s Code of Practice 9 (COP9) is a civil framework under which HMRC’s Fraud Investigations Service (FIS) investigates cases of suspected serious tax fraud. Many readers know of COP9; some may have experienced clients going through it. It is not to be taken lightly.

HMRC estimates that the 2021-22 tax gap (tinyurl.com/hmrcmtg) – the difference between the amount of tax that HMRC thinks it should in theory collect and the amount actually collected – although flat in percentage terms increased to £35.8bn from £30.8bn for 2020-21. The element relating to evasion (deliberate behaviour) increased to £4.6bn from £3.7bn and together with similar behavioural categories (hidden economy and criminal attacks) this accounts for 30% of the 2021-22 tax gap. So while HMRC estimates that it had some success in reducing the criminal attacks tax gap more could be done to tackle...