Code of Practice 8

Code of Practice 8 (COP 8) investigations generally arise where HMRC suspects that a business or organisation has used tax avoidance schemes to underpay tax.


Code of Practice 8 (COP 8) Investigation Specialists

COP 8 usually involves technical tax arguments and generally does not involve allegations of serious tax fraud, so it should remain a civil tax investigation if handled carefully. However, if during the process it appears that HMRC fraud is involved, then it could be upgraded to COP 9 or even a criminal tax fraud investigation.

COP 8 investigations do not have a standardised format and HMRC often focuses on gathering large amounts of information on a business or organisation. It is vital to understand which documents have the protection of privilege and the limitation of what HMRC can obtain.

Richard Nelson LLP’s tax solicitors are specialists in resolving COP 8 investigations. Contact us to see how we can help you.

Every case is different, but areas of interest for HMRC in COP 8 investigations have been Employee Benefit Trusts (EBTs), Investment and Share schemes, Pension schemes, Inheritance Tax schemes, and Transfer Pricing.

Our specialists have significant experience and boast an outstanding success rate in assisting people facing a COP 8 tax investigation.

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How our solicitors can help with COP 8 Investigations

At Richard Nelson LLP, our tax investigation specialists are industry acclaimed. We were named a Leading Firm in The Legal 500 2021. We are well versed in smoothly managing communications with HMRC to ensure that our client’s interests are protected.

Often, a Code of Practice 8 letter is the first negative experience with HMRC that our clients have had. We understand that this can be a nerve-racking process for our clients and those around them.

We can provide the advice and assistance you require when you need it. We can:
- Protect all of our communications with our clients with legal professional privilege, meaning that any communications with our clients cannot be disclosed without their permission (unlike accountants)
- Make certain the investigation process is unobtrusive as possible
- Negotiation to minimise penalties and ‘naming and shaming’
- Ensure the HMRC do not obtain information they are not entitled to
- Ensure that any of your previous tax inaccuracies are resolved as soon as possible

We also maintain working relationships with additional specialists who are sometimes needed, such as forensic accountants and tax barristers, so that we can involve them in your case if necessary.

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What We Do

– Assessing the tax consequences (including challenges to what HMRC state);
– Drafting of responses to HMRC enquiries;
– Representing you and managing any meetings with HMRC;
– Tactics and negotiation to minimise penalties;
– Making a proactive voluntary disclosure to avoid an investigation;
– Avoiding HMRC ‘naming and shaming’;
– Conducting requests for Formal Reviews and Appeals to the Tribunal;
– Making formal complaints;
– Dealing with all contact with HMRC for you;
– Applying Legal Professional Privilege, and Solicitors’ Confidentiality as your safeguards.

Solicitor or accountant?

If you are considering contacting an accountant or a solicitor regarding a COP 8 investigation, you should be aware that information you provide to your solicitor enjoys a special status called legal professional privilege.

Your accountant cannot provide this protection, although they may be able to gain it if they are instructed by a solicitor. If an assessment of the tax due is required, and there is to be a report prepared about your tax affairs, we can instruct an accountant on your behalf.

Get in touch

If you have received a COP 8 letter from HMRC, contact our team without delay and speak to one of our tax litigation lawyers. You can contact our team to request a no-obligation discussion by:

Using the form on this page;
Phoning us during office hours on 0333 888 4040;
Emailing us at

Specialist solicitors

Our multidisciplinary team is made up of specialists in a wide range of services, which means you'll always be represented by an expert in your area.

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Get in touch to arrange a no-obligation, fully confidential call to discuss your case and work out if you want to continue.

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Speak to solicitors in one of our offices throughout England and Wales, or arrange calls and remote meetings.


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