The latest statistics for serious tax investigations which I obtained from HMRC under a Freedom of Information Act 2000 request make interesting reading. My initial focus was on code of practice 9 (COP9) civil investigations of tax fraud where recipients of such notices are challenged as having acted deliberately and fraudulently. They are given an opportunity to admit tax fraud at the outset and to disclose all the irregularities and compute the taxes late payment interest and penalties payable thereon at their own cost. HMRC’s framework in these circumstances allows people and businesses to commission suitably detailed disclosure reports usually prepared by seasoned tax disputes specialists in lieu of lengthy in-depth and intrusive investigations by HMRC.
I also queried statistics relating to code of practice 8 (COP8) investigations where large amounts of tax are considered to be at stake but...
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