Code of Practice 8 – CoP 8 Investigations

Code of Practice 8 – CoP 8 Investigations


If you have received a CoP8 letter from HMRC, it is critical that you obtain specialist advice as you may inadvertently prejudice your case when dealing with HMRC on your own. 

Are you under a COP8 investigation?

CoP8 investigations are dealt with by the Fraud Investigation Service (FIS) at HMRC which carries out civil investigations in certain cases where the Code of Practice 9 is not used.


They would investigate taxpayers who deliberately try to pay less than the correct amount or take advantage of a scheme or device to reduce a tax liability. If FIS suspect this, they will investigate under Code of Practice 8 to establish the facts to recover any tax, interest and penalties due. 


FIS will not undertake this investigation with a view to a criminal prosecution but they may take a different approach if they suspect or find evidence of fraud at any time during their investigation. In such cases, they may then deal with the investigation under Code of Practice 9. Or, if it is being conducted with a view to criminal prosecution, they will investigate under the Police and Criminal Evidence Act 1984 and the Criminal Procedure and Investigation Act 1996 and their respective Codes of Practice. 


Obtaining correct advice


If you have received a CoP8 letter from HMRC, it is critical that you obtain specialist advice as you may inadvertently prejudice your case when dealing with HMRC on your own. Our experts at Templeton Brook Witt specialise in COP8 and COP9 investigations and will provide prompt advice on best course of action and strategy. We take the stress off you by communicating to HMRC directly. With our expert knowledge, we can support you all the way with the aim to bring the investigation to a swift and favourable conclusion. 


If you have received a CoP8 letter from HMRC, contact our specialist Tax Disputes team for a free no obligation consultation today. 


Contact us today

We can help you deal with any tax investigation through expert advice and specialist representation. Our team deals with matters ranging from individual tax disputes to large and complex multiple client cases. 

  • Formal and Informal Notices
  • Compliance Checks
  • Penalty Notices
  • Discovery Assessments
  • Voluntary Disclosures to HMRC
  • Accelerated Payment Notices (APNs)
  • Code of Practice 8 – CoP 8 Investigations
  • Code of Practice 9 – CoP 9 Investigations
  • Contractor Loan Schemes and the Loan Charge
  • DOTAS/POTAS Inquiries
  • PAYE Tax Investigations 


  • Corporation Tax Investigations
  • IR35 Disputes
  • VAT Investigations and Inspections
  • HMRC Unannounced Inspections and Visits
  • Settlements with HMRC
  • Time to Pay Arrangements
  • Statutory Reviews
  • Forensic Tax Advice
  • Tax Litigation Advice
  • Corporate Advisory
  • Private Client Advisory


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