HMRC COP9 Specialist Representation
Led by Shehzad Farrukh FCA & Associates, with more than 36 years of specialist experience
Facing an HMRC Code of Practice 9 (COP9) investigation can be overwhelming. Our specialist forensic accounting team provides experienced representation throughout the Contractual Disclosure Facility (CDF) process, helping you understand your obligations, protect your position and deal with HMRC with confidence.
We guide you through the investigation, assist with HMRC negotiations and work towards the most favourable resolution available in your circumstances.
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FCA -led
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COP9 expertise
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Confidential

HMRC CRISIS MANAGEMENT
Understanding Code of Practice 9 (COP9)
Receiving a Code of Practice 9 (COP9) notice means HMRC suspects deliberate tax fraud. This is not a routine tax enquiry, but a serious investigation with strict deadlines and potentially significant financial, legal and reputational consequences. How you respond at the outset can have a major bearing on the course and outcome of the investigation.

The Contractual Disclosure Facility (CDF)
When HMRC offers the Contractual Disclosure Facility (CDF), you have 60 days to accept or reject the offer and, if accepting, provide a valid Outline Disclosure. Where the CDF terms are complied with and the relevant deliberate behaviour is fully disclosed, HMRC undertakes not to commence a criminal investigation into the suspected tax fraud covered by that disclosure.
The COP9 Forensic Disclosure Report
Following the submission of your Outline Disclosure, HMRC requires a comprehensive, independent forensic audit. Our specialized COP9 tax specialists meticulously prepare the final Formal Disclosure Report. We verify your tax position, calculate precise liabilities, and negotiate directly with the HMRC Fraud Investigation Service (FIS) to heavily mitigate penalties and protect you from criminal prosecution.


HMRC Settlement & Penalty Mitigation
Once the report is submitted, navigating the final meeting with the HMRC Fraud Investigation Service (FIS) requires elite negotiation. We defend your position to dramatically mitigate civil financial penalties, challenge unfair tax calculations, and structure viable HMRC time-to-pay arrangements or settlement terms that protect your personal and business assets.
WHY CHOOSE OUR FORENSIC TEAM
36 Years of Precision: Rapid COP9 Resolutions & Unchallengeable Disclosures
When facing an HMRC Code of Practice 9 (COP9) investigation, time and precision are everything. Backed by over 36 years of specialist forensic accounting experience, our team is built to secure the speedy resolution of complex tax fraud inquiries and reach a definitive final settlement. By accelerating the inquiry timeline, we deliver what matters most to our clients: significantly reduced stress, lower professional fees, and minimized statutory penalties.
This level of efficiency is achieved through a proven, two-part formula: total client cooperation combined with the unshakeable provenance of our forensic reporting. We preach transparency and we practice it religiously. When you make a full and frank disclosure under the Contractual Disclosure Facility (CDF), our meticulous investigation leaves HMRC with virtually nothing to challenge. The result is a seamless, transparent settlement process that satisfies HMRC’s strict regulatory demands while protecting your freedom, reputation, and financial wellbeing.
FIS Defense Expertise
Everyday high-street firms lack routine exposure to the HMRC Fraud Investigation Service (FIS). We handle the intense administrative scrutiny required to firmly protect your interests and reputation.
To ensure complete legal rigor, we work closely with leading tax counsel and specialist barristers. This collaborative strategy allows us to reaffirm our forensic findings, stress-test our disclosure reports, and guarantee strict alignment with the latest tax legislation, statutory updates, and judicial precedents from the Tax Tribunal. By uniting senior forensic accountancy with elite legal counsel, we deliver an unshakeable defense strategy built to withstand HMRC scrutiny.
Forensic Precision
We reconstruct complex, compromised, or missing accounting records to deliver an undeniable Formal Disclosure Report that leaves no room for further HMRC penalties.
By establishing a clear, unbroken audit trail and verifying the precise provenance of all underlying financial transactions, our forensic accounting team minimizes or eliminates speculative HMRC estimates, and leaves no room for further tax fraud penalties or protracted investigation.
Accelerated Resolution & Mitigation
We leverage our specialist experience to drive COP9 investigations to a swift, definitive conclusion under the Contractual Disclosure Facility (CDF). By presenting fully transparent, unchallengeable forensic evidence early, we eliminate unnecessary HMRC delays and prevent fishing expeditions.
This accelerated timeline directly protects your financial wellbeing – drastically lowering overall professional fees, mitigating statutory civil penalties, and removing the prolonged mental stress of an open tax fraud investigation.

