This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Fraud Civil Investigation Manual

Where CDF offer is made 30 June 2014 onwards: opening the investigation: form of opening letter in company cases

As stated in FCIM202040 it is not possible to issue COP9 to a company and the offer of a CDF contract can only be issued to individuals.

In cases involving a company, you must not issue COP9 to all of the directors as a matter of course, see FCIM202040. COP9 should only be issued where your review supports the suspicion of fraud by a particular director. In some cases you might well find that more of the directors are involved or connected to the fraud than you initially thought, and this is when COP9 should be issued to the other directors.

The Code of Practice explains to the director that the investigation will include corporates and other entities.