FCIM202070 - Where CDF offer is made 30 June 2014 onwards: pre-authorisation review and action: authorisation for use of COP9

A registration report must be submitted to the Authorising Officer. This report should include:

• a brief history of the person (including details of any health issues and any reasonable adjustments required)
• the nature of alleged offence
• the extent of evidence of suspected evasion and the estimated arrears, and
• a view on the customer’s ability to pay including comments on liquidity.

It must also highlight what investigation will be needed in the event that the person fails to cooperate with COP9 or makes a denial of irregularities.

The report needs to be sufficiently detailed to enable the Authorising Officer to review the recommendations that have been made and make an informed judgement based on the merits of the case. The Authorising Officer’s decision to agree registration is an important one that should be given serious consideration. A decision to proceed to registration commits HMRC, and often the customer, to considerable expense.

The review needs to consider the likelihood of offences in both direct and indirect taxes. This will help make sure that any guidelines for the type of approach used are followed, and prevent inconsistencies in approach if there are offences in more than one tax regime.

The case is formally adopted under COP9 on the date on which the Authorising Officer approves the case and the referring caseworker’s recommendation.