There have been recent press reports, based on data received by Bureau of Investigative Journalism, that the number of civil enquiries undertaken by the Fraud Investigation Service (FIS) into offshore, corporate and wealthy has halved in five years.

This may be a concern, but it is important to understand FIS’s role in HMRC’s compliance’s activities. Originally a creation of the former Inland Revenue, FIS is an elite specialist unit tasked with undertaking civil and criminal enquiries. The civil enquiries were conducted under Code of Practice 9 (COP 9) where serious fraud was suspected and Code of Practice 8 where COP 9 was not considered appropriate.