What is a Contractual Disclosure Facility (CDF)?
Tax fraud is a criminal offence. Every year hundreds of individuals are prosecuted by HMRC for knowingly failing to comply with their tax obligations. However, when HMRC opens a COP9 investigation, the recipient is also sent a contractual agreement known as the Contractual Disclosure Facility (CDF). The CDF underpins all COP9 investigations and, when accepted, forms a legally binding agreement between HMRC and the taxpayer.
In essence, when the CDF offer is accepted, taxpayers who make a full and accurate disclosure of the irregularities in their tax affairs will be immune from prosecution. This is a one-time offer made at the outset of a COP9 investigation and taxpayers will not be given the same opportunity again.
