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What is Code of Practice 8 (COP8)?


Code of Practice 8 is a leaflet issued by HMRC (usually by HMRC Fraud Investigation Service (FIS) in cases where they suspect that the individual has instigated tax planning that they do not believe works or where they have reason to suspect that all taxes have not been paid.

Where HMRC issue Code of Practice 8 or Requirement to Correct it should always be noted that HMRC do not, at the time of issue, suspect that a person has deliberately taken illegal steps to reduce their tax bill (ie tax fraud or tax evasion).

It would appear that HMRC are now targeting people with offshore interests using Code of Practice 8.

This is a change in approach as for the last few years Code of Practice 8 (COP 8) has generally be used to target marketed tax planning such as:

  • Disguised Remuneration Planning (Loans from Companies)
  • Film Partnership Planning
  • Inheritance Tax Planning involving trusts.
  • Employee Benefit Trusts
  • SDLT Planning involving options and sub sale relief.
  • Any other planning where the law requires that a DOTAS number be issued to the person using the planning.

Due to the challenge to all of these tax planning arrangements, including retrospective legislation to claw back funds HMRC believe are due, along with legislation introducing heavy penalties on accountants who provide tax planning that is legislated against the use of COP 8 has declined as the amount of “unauthorised” tax planning has reduced.

Read more about Code of Practice 8 (COP8).

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Here to help, not to judge
Tax Investigation Specialist
Scott Gilbert, Partner and Tax Investigation Specialist

"We understand that people sometimes make mistakes in their dealings with HMRC and that HMRC make mistakes in dealing with taxpayers. Many people do not know how to deal with HMRC or who to turn to for help resolve the tax dispute.

Our firm of tax advisors specialise in resolving people's problems with HMRC. We have extensive expertise in dealing with all forms of tax investigations and tax disputes as well as with taking matters to the Tax Tribunal where agreement cannot be reached.

We deal both directly with the individual who is under enquiry and also work with many firms of accountants supporting them in dealing with HMRC disputes and advising them on how to handle HRMC to get the best result.

The fact is that proper management of HMRC is the best way of reducing the tax, interest and penalty as well as the time taken in resolving any tax dispute.

Our expert team are none judgemental and rigorously defend your position within the scope and parameter of the law. We take control and manage the process to minimise the interruptions that any form of tax investigation causes to an individual's life and business."