Code of Practice 8

If, for instance, COP 9 is not appropriate, or there is no evidence of dishonesty, the Fraud Investigation Service at HMRC may instead choose to conduct an investigation under COP 8.

The investigation will then be carried out on a civil basis but if HMRC suspect serious fraud during the course of their investigation then they can deal with the investigation under Code of Practice (COP9).

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It is important that care is taken with a COP8 investigation as, unlike COP9, there is no guaranteed protection from a criminal investigation.

As part of their investigations under COP8, HMRC often require sight of a large amount of records and they will not hesitate to approach third parties if the information is not forthcoming from the taxpayer. These cases are often complex, and usually cover cases where large amount s of tax is at stake.

Again, it is important to obtain the right professional advice as early as possible to ensure the case runs smoothly to mitigate the problems and obtain a settlement.