At Beever and Struthers, we know that being contacted by HMRC under their Contractual Disclosure Facility (CDF) can feel overwhelming. It’s serious and it’s personal. But you don’t have to go through it alone.
The CDF is part of HMRC’s Fraud Investigation Service and is used in cases where they suspect tax fraud. It’s governed by Code of Practice 9 (COP9) and offers individuals an opportunity to admit to tax fraud in exchange for immunity from criminal prosecution provided a full and honest disclosure is made.
Whether you’ve received a CDF letter or are considering making a voluntary disclosure, our specialist Tax Dispute Resolution team is here to help. We offer tailored, partner-led support throughout the process, ensuring you understand your options, obligations, and rights.
What’s changed?
HMRC updated their guidance in June 2023, reinforcing the importance of full co-operation and complete disclosure. If you’re facing this situation, early professional advice is vital.
Five Key Considerations Before Engaging with COP9
- Is COP9 right for your situation?
The CDF is specifically for those who knowingly submitted incorrect tax returns or didn’t comply with tax obligations. If your errors were accidental, this may not be the right route. Admitting deliberate errors without good reason can lead to your details being published by HMRC or being flagged in their Managing Serious Defaulters programme. It’s a decision that shouldn’t be made lightly; our team can help assess your position clearly and confidentially. - Understanding what cooperation really means
Once you accept HMRC’s offer of CDF, they expect full co-operation. This can include attending meetings, sharing detailed records, and working within strict deadlines. If you’re unsure what’s expected, or need support managing those expectations, we’re here to guide you sensitively and thoroughly. - Making a full and complete disclosure
HMRC isn’t just looking for information about deliberate errors they also want to understand any non-deliberate mistakes that may have led to tax loss. A well-prepared disclosure, supported by the right documentation, is critical to maintaining your immunity from prosecution. We’ll help you prepare this properly and stay compliant. - Planning payments and managing finances
HMRC expects an upfront payment on account, with further payments as the investigation continues. This helps reduce interest charges (now at 8.25 % since May 2025) and shows good faith. If you need time to pay or need to sell assets to fund repayments, early communication with HMRC is something we can support you with. - Accessing support if you need it
If there are personal circumstances that could make the investigation more difficult to manage, health concerns, caring responsibilities, or anything else it’s okay to speak up. HMRC may adapt their process through their extra support unit, and we’ll help make sure your situation is considered fairly.
How We Can Help
Our Tax Dispute Resolution team are specialists in complex HMRC enquiries, including COP9 disclosures and voluntary settlements. What sets us apart is the way we work: partner-led, responsive, and always human.
We offer:
- A calm, confidential space to explore your options.
- Direct access to a small, experienced team who know the CDF process inside out.
- Guidance that’s honest, clear, and jargon-free!
- Hands-on support with drafting Outline Disclosures, liaising with HMRC, and preparing for meetings.
- From the moment you receive a CDF letter. or even before we’re by your side.
