Code of Practice 8

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Code of Practice 8 (COP 8) Investigation Specialists

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Code of Practice 8 investigations, otherwise known as COP 8, generally arise where HMRC suspect that artificial tax arrangements or avoidance schemes have been used to underpay tax. COP 8 is unlikely to involve allegations of serious tax fraud and 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 full tax fraud investigation.

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

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 via the following means:

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.

Who Can Help You?

Jonathan Wright


Mark Wilson, Partner at Richard Nelson LLP

Mark Wilson


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What we do...

Our team contains experienced COP 8 investigation lawyers and solicitors. We know how important it is to resolve Code of Practice 8 investigations quickly, whilst also protecting you liberty and privacy, and restricting the financial consequences. Our tax investigation services include:

  • Immediate responses to dawn raids, arrests and interviews under caution;
  • The quick arrangement of advice and assistance for you, including meeting as appropriate, for all aspects of COP 8 investigations;
  • Drawing upon close working relationships with independent tax consultants, forensic tax accountants, and specialist tax barristers, so that we can involve them in your case if necessary;
  • Helping you to avoid a HMRC criminal investigation if one has not already started, by a carefully managed disclosure to HMRC where appropriate;
  • Minimising the effects of an existing tax fraud investigation and helping to convert it to a civil solution;
  • The robust defence of a tax fraud prosecution, including challenging Restraint Orders and Confiscation proceedings;
  • We act for taxpayers anywhere in England and Wales, including in London (but not at London prices).

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