“COP9 case study – the conclusion” by Anton Lane, industry recognised specialist dealing with contentious tax issues

In the final part of his three-part series, Anton Lane concludes the tale of Scott and a COP9 disclosure Six months of Scott’s life had passed between the opening meeting and the submission of his disclosure report. During that period, Scott had some anxiety although did not suffer as bad as other clients. The anxiety normally derives from not knowing what the tax, penalties and interest might be.

There is also concern about the impact on a relationship and the family. It is not unusual for a spouse to be unaware of
the tax irregularities and to be drawn into the disclosure process by virtue of being a shareholder, etc.

Scott’s wife was a shareholder. We had carefully explained the COP9 process and reassured her that the events giving rise to the irregularities were not entirely unusual. Obviously, we reassured her the disclosure could be managed and whilst an inconvenience at times, it would be concluded as quick as possible.

The time to conclude a COP9 can vary tremendously. The CDF framework was put in place to try to quicken the time taken to settle. The reality is it takes a considerable amount of time to review information going back twenty years, reconstruct accounts, prepare tax calculations, consider technical arguments and present the irregularities to secure the best position for a client. If an adviser suggest that the settlement will follow shortly after the submission of the disclosure report, they will mostly be giving false hope.

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