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You may have seen media coverage concerning HMRC’s use of account holder information stolen from HSBC in Switzerland. It is now evident that HMRC has reviewed the information and has launched a concerted attack against tax evasion on the strength of it. We have recently seen a flurry of new tax investigations under Code of Practice 9 [COP9] - Civil Investigations into Cases of Suspected Serious Tax Fraud as a consequence of HMRC being passed information on HSBC customers who have accounts in Switzerland. Investigations under COP9 are the most serious non-criminal tax investigations that HMRC undertakes. These enquiries are being led by HMRC’s most elite investigators at Specialist Investigations [SI], with the recent cases originating from the Glasgow office.