UK crypto tax specialists
Code of Practice 9 and the Contractual Disclosure Facility
Code of Practice 9 is HMRC's civil route for suspected deliberate tax fraud. It offers immunity from prosecution in exchange for a complete and accurate disclosure within 60 days.
- HMRC Cryptoasset Manual applied line by line
- Timestamped pricing feeds for every valuation
- Pooling and the 30-day rule handled correctly
Code of Practice 9 is issued by HMRC's Fraud Investigation Service where it suspects deliberate conduct has caused a loss of tax. It carries an offer: the Contractual Disclosure Facility, under which HMRC agrees not to pursue a criminal investigation into the conduct you disclose, provided your disclosure is complete and accurate. This is the most serious civil correspondence a taxpayer can receive, and the response window is 60 days.
The three possible responses
- Acceptance. You sign the outline disclosure, admitting deliberate conduct and setting out its nature. Immunity from prosecution for the disclosed conduct follows. A full report, prepared to HMRC's standard, comes later.
- Denial. You state that no deliberate conduct occurred. HMRC then investigates on its own terms, and the criminal option remains open.
- No response. The worst outcome. The offer lapses, immunity is lost, and HMRC proceeds regardless.
The choice is irreversible in practical terms and should never be made without specialist advice. An acceptance that understates the conduct forfeits the protection it was meant to secure.
Why crypto cases end up in COP9
Deliberate conduct in a crypto context is rarely exotic. It is typically repeated non-declaration across several years after the taxpayer knew reporting was required, use of offshore or non-KYC venues to place gains beyond visibility, or a nudge letter answered with a false certificate of tax position. Once HMRC concludes the behaviour was deliberate, the case is escalated.
How we work these cases
- Assess the strength of HMRC's position and advise on acceptance or denial before the 60-day deadline.
- Draft the outline disclosure so it is complete on the conduct without conceding matters that are not established.
- Reconstruct the full transaction history and quantify tax, interest and penalties for every year in scope.
- Prepare the disclosure report and supporting schedules to the standard HMRC expects from a professional adviser.
- Represent you at meetings, negotiate the penalty and behaviour position, and agree the settlement contract and payment terms.
Where privilege or a genuine criminal risk is in play we work alongside specialist tax counsel and solicitors, and we will say so at the first meeting rather than after.
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- HMRC Cryptoasset Manual applied line by line
- Timestamped pricing feeds for every valuation
- Pooling and the 30-day rule handled correctly