If you or your client is under serious tax investigation by HMRC FIS, it is crucial that this is managed by a specialist. Our award winning tax disputes team cover HMRC civil tax investigations and share how they can guide you through the process.

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HMRC’s Fraud Investigation Service (FIS) conduct serious civil tax investigations under Code of Practice 8 (COP8) or Code of Practice 9 (COP9). HMRC’s FIS is HMRC’s elite investigation office. Its officers should be respected and not under-estimated.

Code of Practice 8 tax investigation

HMRC COP8 tax investigations are only opened in circumstances where HMRC holds suspicion that the taxpayer has underpaid a significant amount of tax through complex tax arrangements or structures, particularly involving offshore aspects. HMRC’s FIS aims to successfully challenge your tax affairs and to recover tax, interest and penalties. If you are placed under a COP8 tax investigation, you should immediately seek specialist advice to help and guide you around the potential pitfalls to ensure you are best protected and reduce the liability that might otherwise be due.Should HMRC FIS establish evidence of tax fraud or irregularities resulting from deliberate or concealed behaviour, they may change the investigation to COP9 status or even commence a criminal investigation.

Code of Practice 9 tax investigation

A COP9 investigation is undoubtedly the most serious type of civil investigation undertaken by HMRC’s FIS. A COP9 investigation is only opened in circumstances where HMRC’s FIS suspects an understatement of tax and believes the underlying reason for that irregularity is a taxpayer’s dishonesty and intention to commit fraud. Taxpayers are given 60 days to accept or reject HMRC’s Contractual Disclosure Facility (CDF) offer. The CDF offer gives taxpayers the chance to disclose any loss of tax to HMRC that has been brought about by deliberate conduct. Specialist advice about the potential consequences of accepting or rejecting the CDF offer is imperative. Further information on HMRC COP9 and the CDF offer can be found on our .