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HMRC Code Of Practice 8.

HMRC Code of Practice (COP8) tax investigations are only opened where HMRC suspects a serious loss of tax by a taxpayer typically having taken advantage of a scheme or device to reduce a liability that might otherwise be due.

COP8 tax investigations are only conducted by HMRC’s elite investigation offices, who should not be under-estimated. Traditionally, the COP8 procedures are used to challenge tax planning arrangements entered into by clients or, more recently, to enquire into disclosures made under the Liechtenstein Disclosure Facility. HMRC’s aim is to successfully challenge the position and to recover tax, interest and penalties. Should HMRC establish evidence of tax fraud or irregularities resulting from deliberate or deliberate and concealed behaviour, HMRC may change the investigation to Code of Practice 9 status or even commence a criminal investigation. Should you be placed under COP8 tax investigation, you should immediately seek specialist advice to help and guide you around the potential pitfalls to ensure you are best protected.  Moreover, HMRC openly advise those subject to a COP8 tax investigation to seek expert help.

How can we help?

COP8 tax investigations are typically complex and can often be contentious. They usually involve significant sums of tax and should be handled by practitioners who have experience of dealing with such investigations.

We have successfully represented numerous clients under COP8 tax investigation.  Our expertise quickly allows us to assess, understand the technical issues and provide you with an open and honest viewpoint as to any exposure to UK tax you may face. Should we consider there to be exposure, we will obtain you the most favourable settlement terms available.  Should we believe your tax affairs to be correct, we will defend your position and will meet with HMRC at the earliest opportunity to identify HMRC’s main concerns and, where possible, satisfy them.

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