HMRC Tax Investigations – COP8 and COP9

Helpline

Call our confidential Tax Dispute Resolution Helpline for a no obligation conversation with one of our team to discuss your tax problem and see if we can assist.

Call our tax dispute resolution helpline now: 0800 0113 451

If HMRC has notified you that they are investigating your tax affairs under a COP8 or COP9 investigation, it can be both stressful and distract you from both your personal and business life.

Our 40-strong team’s expertise spans the full spectrum of tax investigations. We can help you resolve any dispute quickly and effectively, and our relationships with banks, lawyers and wealth managers means that no matter how complex your situation, we have the expertise to help.

At the core of our approach lies proactive engagement – with you, with HMRC and your advisers. We take the lead in identifying any potential issues before they escalate. By collaborating closely with you, we can streamline the investigation process, alleviate stress and make sure your tax affairs are up to date and compliant.

COP8 Tax Investigations

Code of Practice 8 (COP8) investigations are used if HMRC deliberately suspects an individual or entity has underpaid their taxes through complex arrangements or structures.

Unlike routine compliance checks, COP8 investigations fall under the remit of HMRC's Fraud Investigation Service (FIS), a specialised compliance team equipped to handle complex tax matters. During a COP8 investigation, HMRC often request extensive documentation to understand your financial affairs thoroughly and we can guide you through the process.

If you have received a COP8 notification from HMRC it is essential to seek professional advice from qualified tax specialists as COP8 investigations can be complex and can have significant financial and legal implications.

Our team’s deep understanding of COP8 investigations ensures we can smoothly guide you through the process. This allows us to anticipate potential challenges and formulate the most effective strategy, maximising your chances of a successful outcome.

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COP9 Tax Investigations

HMRC uses Code of Practice 9 (COP9) to investigate suspected serious tax fraud or deliberate errors/omissions.

Tax fraud is a criminal offence, but HMRC will often settle matters through the COP9 civil procedure, called the Contractual Disclosure Facility. Their aim is to agree a financial settlement where you pay the tax, late payment interest and any penalties you owe.

If you receive a COP9 letter from HMRC, you should use an experienced adviser to guide you through this complex process because of the potentially serious implications of not engaging fully with it or fully understanding the risks of not doing so. Although HMRC gives you an initial 60-day deadline to reply, a lot needs to be done before you respond, so instructing an expert adviser quickly is paramount. Our team has many years’ experience supporting clients through the COP9 process, gained both as tax advisers and from within HMRC's Fraud Investigation Service. Across our team, we have handled some of the largest and most complex COP9 investigations opened by HMRC.

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