Code of Practice 8 is the set of rules HMRC’s Fraud Investigation Service (FIS) adheres to when it is investigating a taxpayer on a civil basis and fraud is not suspected.
COP8 has latterly been the route used by HMRC to investigate disclosures made through the Worldwide Disclosure Facility, particularly where large sums are involved and/or HMRC have concerns over an individual’s domicile.
Any investigation led by HMRC’s FIS team should be handled with care, preferably by a Tax Dispute Resolution expert.
Any taxpayer under Code of Practice 8 investigation by HMRC should seek specialist Tax Dispute Resolution advice. Whilst this is the route HMRC use when they do not suspect tax fraud, unfortunately, it is also believed to be a route used by HMRC when they do suspect tax fraud and do not want the taxpayer to receive the immunity from prosecution offered by Code of Practice 9 process.
A tax specialist can request to make a disclosure in accordance with COP8. This could be beneficial when there is no admission of deliberate behaviour but there is a complexity that would benefit from a particular HMRC specialist being involved.
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