Prior to 31 January 2012, cases of suspected serious tax fraud were dealt with under the Civil Investigation of Fraud process by specialist offices of HMRC. This process, once started provided an absolute guarantee that the person under investigation would not be prosecuted for the original tax offences.
Over the years, HMRC felt that this process was not always being taken seriously by those under investigation and their advisors and was not being afforded the level of co-operation it deserved. Out of this sense of frustration Code of Practice 9 was born.