Where CDF offer is made up to 29 June 2014: pre-authorisation review and action: the role of the Authorising Officer
COP9 can not be issued unless this is approved by the Authorising Officer, (see FCIM102060 for a definition of an Authorising Officer) who needs to apply basic tests to cases when deciding if registration is appropriate.
Whilst there are generally no minimum amounts of tax at risk, the amount of potential lost revenue will be a consideration in determining if COP9 will be used. In the case of a request from the taxpayer for the offer of CDF the amount involved in the fraud will often not be known at the outset (see FCIM102010 and FCIM102060). In itself the lack of certainty about the amount involved must not prevent COP9 being used.
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)