Independent analysis in
HMRC fraud investigations.
Key Ledgers provides forensic accounting analysis in HMRC Code of Practice 8 and Code of Practice 9 investigations, reconstructing financial and tax positions from underlying records.
The real position, independently reconstructed.
COP8 and COP9 investigations turn on the figures HMRC relies on - figures often built on incomplete records and assumptions. We reconstruct the true financial and tax position from primary records and test the basis of HMRC's calculations.
Every analysis is prepared independently and to CPR Part 35 standard where an expert report is required, giving advisers a defensible basis for the response.
Discuss an InstructionReconstructing the position HMRC relies on.
A robust response to a COP8 or COP9 investigation needs an independent, evidenced view of the actual position. We rebuild the financial and tax position from the records, identify where HMRC's assumptions overstate the liability, and present the analysis to support the disclosure or defence.
Reconstruction of the financial and tax position from bank records, accounting records and third-party documentation where the existing records are incomplete.
Independent review of HMRC's figures and the assumptions underlying them, identifying where the assessed liability is overstated or unsupported.
Forensic support for the Contractual Disclosure Facility and disclosure reports, providing the underlying figures that support an accurate and complete disclosure.
Where required, CPR Part 35 compliant expert reports and analysis to support the taxpayer's position in proceedings.
COP9 Reconstruction and Disclosure
Instructed to reconstruct the financial and tax position of a taxpayer under COP9 investigation. The existing accounting records were incomplete and HMRC's own calculations contained assumptions that overstated the position. The reconstruction produced an evidenced set of figures that supported the disclosure.
"Bharat provided clear and well-reasoned forensic accounting analysis... His work was instrumental and proved valuable in supporting the legal arguments advanced in the proceedings."
Andrew Barns-Graham, Barrister, 3 Hare CourtBharat provided clear and well-reasoned forensic accounting analysis. His work was instrumental and proved valuable in supporting the legal arguments advanced in the proceedings.
Andrew Barns-GrahamBarrister, 3 Hare CourtInstructions
Practice
Expert
HMRC investigation questions answered.
If your question is not covered below, contact us directly and we will respond the same working day.
- Code of Practice 8 is used by HMRC where it suspects a significant tax loss but is not alleging fraud, often involving complex avoidance. Code of Practice 9 is used where HMRC suspects serious tax fraud and offers the Contractual Disclosure Facility. Both require an accurate, evidenced reconstruction of the financial and tax position, which is the work we provide.
- Yes. We independently review HMRC's calculations and the assumptions behind them. Where the assessed liability is overstated or unsupported by the records, we set out an evidenced alternative based on the actual reconstructed position.
- For a Contractual Disclosure Facility disclosure we reconstruct the underlying figures from primary records so the disclosure report is accurate and complete. An evidenced figure base supports a credible disclosure and a sound negotiating position.
- Yes. We work alongside the taxpayer's solicitors and tax advisers, providing the forensic accounting analysis that underpins the response, the disclosure or the defence, and acting as an independent expert where a report is required.
- Where the matter proceeds and an expert report is required, the report complies with CPR Part 35 and the accompanying Practice Direction, with the required declaration and the expert's overriding duty to the court.
Reconstructing fund flows and the source and application of funds.
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Preferences, transactions at undervalue and recovery for officeholders and Counsel.
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Forensic accounting and quantum across commercial and shareholder disputes.
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We respond to all enquiries the same working day. Instruction details are treated as confidential from the first contact.
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COP9 and the Contractual Disclosure Facility Explained
How a COP9 investigation works and why the disclosure figures must be reconstructed from the records.
When HMRC's Assumptions Overstate the Liability
The common assumptions in HMRC calculations that an independent reconstruction can correct.
Reconstructing a Tax Position From Incomplete Records
How forensic accountants rebuild the financial and tax position when the records are incomplete.