Are you under a Code of Practice 8 or COP 8 tax investigation from HMRC?
This is a serious tax investigation and if not handled correctly by a specialist, can possibly turn into a criminal tax investigation. Churchill Tax Investigation specialize in Code of Practice 8 or COP 8 tax investigations and will advise you on best possible options and strategy.
What is a Code of Practice 8 enquiry?
The Specialist Investigations division of HMRC is responsible for the completion of investigations using the Code of Practice 8 or COP8 Procedure in all instances where COP 9 procedures are not used. Where HMRC suspect the tax payer of deliberately paying less tax than they should or taking advantage of a scheme to reduce tax liability, they will conduct an in depth investigation. In line with the COP 8 procedure, HMRC will take steps to recover the tax that is owed along with any interest and penalties. Although these investigations are not carried out in line with criminal proceedings, they suspect that or find actual evidence of fraud, they can take further action and launch a COP 9 investigation.
Appointing a Code of Practice 8 specialist or Consultant
HMRC will recommend that anyone who is subject to a Code of Practice 8 or COP 8 tax investigation should consider instructing an experienced tax investigation specialist and that is where we can help. We have extensive experience in the delivery of tax investigation advice to a range of businesses and individuals. Using our knowledge we can support you throughout the process, attending the necessary HMRC meetings and preparing information that you need to help resolve any enquiries. Churchill Tax Investigations will work with you to facilitate the investigation and bring it to a swift conclusion. If you can help communicate that there is nothing wrong with your tax affairs, the matter will be closed and you will face no penalties or implications. If HMRC find something of concern, they will mitigate any losses by recovering the tax payable along with any penalties and interest.
HMRC will usually initiate a Code of Practice 8 investigation when they believe that a significant amount of tax has not been paid as a direct result of deliberate behaviour or tax avoidance schemes or arrangements. From the outset, these investigations generally do not involve any allegation of a serious fraud. However, any COP 8 investigations should still be treated seriously as these can lead to COP 9 Investigations which are considerably more serious and can lead to prosecution.
During a COP 8 investigation, the focus will be on gathering a significant amount of information. Therefore it is beneficial to understand what HMRC can actually collect because there is no standardised procedure for a COP 8 investigation.
Our expertise in relation to COP 8 investigations
Churchill Tax Investigations take a positive and proactive approach to all tax investigations, no matter how complex they may be. We not only aim to reduce the amount of information that you have to present to HMRC but you will also have to meet with HMRC in the initial stages of the investigation to identify their concerns and ensure that the enquiry does not turn into an investigation to simply obtain information. As specialists in this area we can ensure this doesn't happen. Our team comprises of highly qualified tax specialists and ex- HMRC officers who have decades of experience in dealing with Code of Practice 8 and 9 enquiries.
Although it is not compulsory to create a report for submission to HMRC, it is often a good idea to collate the information and documents into a report and we can help you with this process. A comprehensive report can help you put everything into context, present the relevant technical aspects and avoid protracted correspondence.
With extensive COP 8 investigation experience, we will work with you to bring the investigation to a quick resolution with minimum disruption to your business.
How we can help
Take full control of the Code of Practice 8 investigation
Liaise with HMRC in relation to COP 8 enquiry
Liaise with client’s accountants in relation to the COP 8 investigation
Meet with HMRC and set strategy in relation to COP 8 Investigation
Provide advice on best options in relation to the Code of Practice 8 enquiry
Agree a settlement with HMRC officers in relation to Code of Practice 8
Mitigate tax penalties
Conclude matters as soon as possible in our client’s favour