COP8 specialist investigations
Where HMRC considers a case significant enough for its specialist investigators, but is not alleging fraud. Materially more serious than a routine compliance check.
What COP8 signals
A COP8 investigation means HMRC has allocated specialist resource to your affairs. It is used where a case is complex, where substantial amounts are involved, or where HMRC is examining arrangements it regards as tax avoidance. It does not carry an allegation of fraud — that is what COP9 is for.
The distinction matters, but so does what it has in common with COP9: these are investigators who do this work full time, and the case has been selected deliberately.
The line that can move
A COP8 investigation is not fixed in place. If evidence of deliberate conduct emerges during the investigation, HMRC can change its approach, and the position becomes a materially different one. How the early exchanges are handled is therefore not only about the current investigation.
What we do
- Establish the scope of what is actually being investigated
- Take over correspondence and attend meetings with HMRC
- Work out the technical position properly before adopting one with HMRC
- Draft every response, and identify requests that fall outside the investigation
- Advise on disclosure where the facts warrant it, rather than by default
- Refer the matter on where it needs counsel or a larger investigations team
If your letter refers to Code of Practice 9 rather than Code of Practice 8, the position is different and the deadlines are strict. See COP9 and the Contractual Disclosure Facility.
Common questions
What is Code of Practice 8?
COP8 is used by HMRC specialist investigators where a case is significant or complex but fraud is not being alleged. It commonly covers arrangements HMRC considers to be tax avoidance, and cases involving substantial amounts or complicated structures.
How is COP8 different from COP9?
COP9 is issued where HMRC suspects deliberate conduct bringing about a loss of tax, and offers the Contractual Disclosure Facility. COP8 does not carry that allegation. However, if evidence of deliberate conduct emerges during a COP8 investigation, HMRC can change its approach.
Is COP8 more serious than a normal compliance check?
Yes. COP8 is handled by specialist investigators rather than the officers who deal with routine compliance checks, and the cases selected for it are ones HMRC considers to warrant that resource.
Should I handle a COP8 investigation with my usual accountant?
That depends on their experience of investigations specifically. Preparing accurate accounts and defending a specialist investigation are different disciplines, and a practice that does not routinely handle the latter may be better placed to refer it on.
Start with the letter
Send a photo of page one on WhatsApp. We will tell you what it is, what the deadline means, and what a fixed fee would look like — within one working hourduring monday to friday, 9am to 5pm.
We only need the letter. Please do not send bank statements, identity documents or your UTR at this stage.