Code of Practice 9 (COP9)

Code of Practice 9 (COP9)

Receiving a Code of Practice 9 (COP9) letter from HMRC is a serious matter that requires immediate attention. This letter indicates that HMRC suspects deliberate tax fraud has taken place and initiates a formal investigation. How you respond in the coming weeks can...
Tax Disputes and Investigations – December 2025

Tax Disputes and Investigations – December 2025

This newsletter picks up a number of issues which arose from the November budget which will be of particular interest to those involved in tax disputes.  Additionally, we have focussed on some new ‘Guidelines for Compliance’ issued by HMRC which has interesting...
Tax Disputes and Investigations – July 2025

Tax Disputes and Investigations – July 2025

HMRC reactivates enquiries into unallowable purpose Ben Proctor HMRC has been writing to taxpayers with open enquiries involving the unallowable purpose rule at Section 441 CTA 2009. The letters invite taxpayers to reconsider their position in light of three Court of...
Tax Disputes and Investigations – November 2024

Tax Disputes and Investigations – November 2024

The Autumn Budget contained several high-profile measures which have obviously been the subject of considerable debate since.  In this month’s newsletter, we have looked at some of the immediate announcements which may be specifically relevant for those dealing...
Tax Disputes and Investigations -October 2024

Tax Disputes and Investigations -October 2024

Alternative Dispute Resolution (‘ADR’) By Jon Preshaw ADR is an increasingly important part of the toolkit available to practitioners and HMRC to resolve disputes.  Our recent experience is that HMRC are keen to engage through ADR in most circumstances.  In...