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What is the Contractual Disclosure Facility?


Being subject to a tax investigation is very stressful for people, but being subject to the contractual disclosure facility arrangements is one step down from being subject to a prosecution for tax fraud.

It is therefore important that people who receive a letter from HMRC offering them the contractual disclosure facility understand the process and implications of being offered the facility.

The contractual disclosure facility is an HMRC process where they suspect serious tax fraud. The facility is only issued with HMRC’s Code of Practice 9 (investigations where HMRC suspect tax fraud). Anyone who received a letter from HMRC with an offer to participate in the contractual disclosure facility should seek professional tax advice from a specialist in dealing with the contractual disclosure facility and Code of Practice 9 tax investigations.

The facility can only be issued by an authorised officer and generally it is only used by HMRC’s Fraud Investigation Service who also deal with suspected serious tax fraud and criminal investigation. Usually HMRC will only issue the offer of the contractual disclosure facility where they believe that there will be duties unpaid of over £75,000 because of the suspected tax fraud.

Read more about the Contractual Disclosure Facility.

If you can't find the answers you are looking for in our FAQ please get in touch with our team for confidential and no-obligation advice.

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Here to help, not to judge
Tax Investigation Specialist
Scott Gilbert, Partner and Tax Investigation Specialist

"We understand that people sometimes make mistakes in their dealings with HMRC and that HMRC make mistakes in dealing with taxpayers. Many people do not know how to deal with HMRC or who to turn to for help resolve the tax dispute.

Our firm of tax advisors specialise in resolving people's problems with HMRC. We have extensive expertise in dealing with all forms of tax investigations and tax disputes as well as with taking matters to the Tax Tribunal where agreement cannot be reached.

We deal both directly with the individual who is under enquiry and also work with many firms of accountants supporting them in dealing with HMRC disputes and advising them on how to handle HRMC to get the best result.

The fact is that proper management of HMRC is the best way of reducing the tax, interest and penalty as well as the time taken in resolving any tax dispute.

Our expert team are none judgemental and rigorously defend your position within the scope and parameter of the law. We take control and manage the process to minimise the interruptions that any form of tax investigation causes to an individual's life and business."