Code of Practice 8

COP 8 is used in cases where there has been a significant loss of revenue to HMRC as a result of a complex tax arrangement or avoidance scheme being used, but usually no suspected fraud.

Why seek advice?

  • These cases can vary widely in scope, which makes it important to seek professional advice before speaking to HMRC.
  • While there might be no suspected fraud at the outset, the investigation should be treated seriously as HMRC will usually believe a large amount of tax is at stake.
  • These cases usually involve a large amount of data gathering and analysis which may be complex.
  • A professional advisor can help you to understand the scope of HMRC’s powers and the information they are able to request from the outset.
  • Your penalties may be significantly reduced if a high quality disclosure is made.

How we can help

  • We take a personal approach and make sure we clarify complex issues so that you are kept fully informed throughout the process.
  • COP 8 enquiries are daunting, but our multi-award winning team has experience from both an HMRC and advisor perspective and can guide you throughout.
  • We take a hands-on approach. Some cases require a robust stance to be taken with HMRC, or a practical or discreet solution needs to be negotiated.
  • We have successfully defended a number of clients who are subjected to enquiries by HMRC.

Contact us

Sean Wakeman
Sean Wakeman
Partner, Head of Tax Investigations
London