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HMRC guidance states that Code of Practice 8 (COP8) is primarily used to investigate cases of tax avoidance. However, there will occasionally be circumstances where HMRC’s Fraud Investigation Service (FIS) wish to investigate a case involving evasion but for various reasons the criteria for using Code of Practice 9 (COP 9) under the Contractual Disclosure Facility (CDF) procedure do not apply. In these circumstances COP 8 will be used instead.

Essentially this relates to HMRC investigating a taxpayer on a civil basis where fraud is not suspected.

COP8 has been used in recent years by HMRC to investigate disclosures made through the Worldwide Disclosure Facility, particularly where large sums are involved and/or HMRC have concerns over an individual’s domicile.

Why is it important

Any investigation led by HMRC’s FIS team should be handled with care with specialist advice sought from a Tax Dispute Resolution expert.

Who needs to know this

Any taxpayer under Code of Practice 8 investigation by HMRC should seek specialist Tax Dispute Resolution advice. It is vitally important to have the right representation in these investigations to ensure that the best outcome is achieved.

Please contact James Cordiner,, tax investigation manager at Markel Tax, for a no obligation and confidential discussion.

Markel Tax is a trading name of Markel Consultancy Services Limited. Registered in England and Wales, company no: 08246256. Registered address:  20 Fenchurch Street, London, EC3M 3AZ. VAT no. 245 7363 49.

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