CoP8 Tax Investigations

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Pannu Tax can provide help and advice around CoP8 tax investigations for clients throughout the UK.

Receiving Code of Practice 8 ("CoP8") means that you are likely to be the subject of an in depth enquiry from HMRCs Specialist Investigations ("SI") team. This part of HMRC contains experienced and skilled investigators charged with completing significant civil settlements of tax, interest and penalties.

VIDEO - CoP8 Investigations

Why have I received a CoP8 from HMRC?

You are not being accused of tax evasion (Code of Practice 9). However, there have been a number of recent cases where the investigator has subsequently switched to CoP9 where, for example, incorrect information has been provided to HMRC or there is other evidence of dishonest behaviour. So, while the CoP 8 may relate to a tax technical issue or marketed tax avoidance scheme, care still needs to be taken to effectively manage the information provided to HMRC and ensure that any written or verbal responses are accurate and cannot be subject to misunderstanding.

What should I do if I receive a CoP8?
  1. Instruct an advisor who is experienced in dealing with these types of investigations, is capable of offering a clear path to resolution and who understands the powers and processes of HMRC.
  2. Engage early with the investigator leading the CoP8 enquiry. Our experience shows that early engagement enables you/your advisor to properly understand the nature and scope of the enquiry and the investigator's concerns (it may be in relation to a particular transaction, offshore structure or tax scheme or it may relate to your tax affairs more generally). Early engagement allows you/your advisor to build rapport with the investigator and helps to focus the enquiry at an early stage. This type of approach can pay dividends later on.
  3. By properly understanding the issues and concerns of HMRC at the start of the enquiry you are better able to manage and understand any subsequent requests for information. Ensuring that the information you provide to HMRC is properly managed and the facts (for example, in personal residence enquiries are effectively presented and articulated can be critical to ensuring a successful and timely conclusion. Understanding what HMRC is legally entitled to obtain is critical (especially, where for example, requests are being made for documents held by overseas entities or other third parties). It also ensures that the risk of HMRC switching to the more serious Code of Practice 9 investigation is reduced.
  4. Ensure that you/your advisor has a clear strategy on how to resolve the investigation and is effective in getting HMRC to engage and buy-in to this. It is unfortunate that some CoP8 enquiries take several years to conclude. In our experience this is often unnecessary and is sometimes caused by either the client and/or the HMRC investigator not focusing on resolution from the start of the investigation. Instead, matters are allowed to drag on for far too long with neither side being prepared to make a decision or getting bogged down on technical matters which may not be crucial to obtaining finality.
  5. Negotiate a settlement that is reasonable and based on the facts and issues that the investigator has been able to prove has led to additional tax liabilities (rather than suggesting or implying it). In cases where the facts are unclear or complex it is important to ensure that the investigator is able to show (on the balance of probabilities) that any claim for additional tax and/or penalty can be supported by the facts rather than by implication or inference. Understanding HMRCs powers to assess and scope to negotiate are vitally important to getting the best possible outcome.

How Can Pannu Tax Help?

At Pannu Tax you will be advised by some the UKs leading tax investigations and dispute specialists who have the practical experience and the technical knowledge required to provide you with the type of effective support you need. They will be able to provide you with clear, consistent and practical advice on how to achieve early resolution of your CoP8 enquiry.

By engaging with Pannu Tax You will have access to their extensive experience and in depth and up to date knowledge of HMRCs procedures, powers and processes (usually only found in the top global accountancy firms) but at an affordable price. Your advisors have dealt with some of the most complex and high profile HMRC investigations in the UK.

To get further information or for a free, confidential and no obligation discussion please contact us on 0800 246 5915, complete the contact form or email us direct at info@pannutax.co.uk.

Expertise & Experience

At Pannu Tax you will be advised by some the UK's leading tax investigations and dispute specialists who have the practical experience and the technical knowledge required to provide you with the type of effective support you need.

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How can we help?

For a free, confidential and no obligation discussion call us on 0800 246 5915 or email us direct at info@pannutax.co.uk


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