United Kingdom — Contractual Disclosure Facility (Code of Practice 9): sourced answers
1 answer to specific questions — each with a verbatim quote from an official source and a link to it.
Every answer is checked against a verbatim quote from a stored copy of its source and has passed an independent review. This is reference information, not legal advice: rules change, and the outcome depends on your circumstances.
Tax regime
Does the regime (disclosure, amnesty) protect from criminal prosecution
Yes, by contract: HMRC undertakes not to open a criminal investigation into the conduct disclosed, provided the disclosure is complete
«Under the terms of the CDF , we invite you to disclose all your deliberate behaviour that has brought about a loss of tax or duty, or payment administered by HMRC. Where deliberate behaviour is disclosed, HMRC undertakes not to commence a criminal investigation into the suspected fraud connected with this disclosed behaviour. The CDF is a contract offered by HMRC and accepted by the individual under investigation where both parties agree to be bound by its terms. HMRC will not offer the CDF on any other terms. The CDF offers you the chance to disclose: your deliberate behaviour that brought about a loss of tax, duty or payment administered by HMRC and any other irregularities in your tax affairs The CDF is only suitable for you if your deliberate behaviour has brought about a loss of tax, duty, or payment administe»
Source: gov.uk · source copy as of 2026-10-02
«If you accept the offer of the CDF and make a full disclosure of your deliberate behaviour, we will not pursue a criminal investigation. However, you may be liable to pay civil penalties. Your level of cooperation will be taken into account in assessing any civil penalties due. As a rule, the more you cooperate, the lower the penalty will be. You must stop any deliberate behaviour that has led, or which may lead to a future tax or duty loss immediately. You must keep all existing records including any computer records, during the investigation whether or not you are required by law to do so. We may ask to see your business and private financial records. A»
Source: gov.uk · source copy as of 2026-10-02
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