The new Contractual Disclosure Facility

HMRC launched its Contractual Disclosure Facility (CDF), the latest incarnation of HMRC’s civil investigation of fraud procedure, on 31 January. The CDF was launched partly in response to NAO criticism, and also due to the pressure to increase tax revenues. A significant difference from the former Civil Investigation of Fraud (CIF) procedure is that taxpayers suspected of fraud no longer have automatic protection from prosecution. Taxpayers can voluntarily seek entry into the CDF. However, the CDF will not automatically be given to a taxpayer who requests it. For many taxpayers with serious irregularities, the (recently extended) Liechtenstein Disclosure Facility will provide a better solution.