HMRC's Fraud Investigation Service (FIS) issue their Code of Practice 8 leaflet when they suspect that a taxpayer has underpaid a significant amount of tax through complex tax arrangements or structures.

CoP 8 tax investigations have been used to challenge tax planning where the law requires that a DOTAS number be issued to the person using the planning. CoP 8 is also used to challenge other marketed tax planning schemes such as Disguised Remuneration Planning (Loans from Companies), Film Partnership Planning, Inheritance Tax Planning involving trusts, Employee Benefit Trusts and sophisticated SDLT planning.

Also at risk of Code of Practice 8 tax investigations is tax planning that involves offshore structures and/or overseas links. HMRC will often use CoP 8 when they suspect that the taxpayer has undertaken tax planning to mitigate their UK tax exposure and to take advantage of their domicile or residence position.

Tax Advisers

The following advisers all have the relevant specialist expertise. Their profiles include their contact details, background, specific expertise and other specialisms

David Logan
David Logan
Chartered Tax Adviser for over 25 years and a member of the CIOT. Specialised areas of tax include dealing with tax avoidance schemes and HMRC tax investigations
Nick Davies
Nick Davies
Highly experienced professional dealing with HMRC disputes of all types across the whole of the UK. Over 40 years in the sector to include leadership positions in large firms.
Barbara Bento
Barbara Bento
Using my technical expertise and intricate knowledge of HMRC, together with my mediation and people skills, I help my clients resolving complex tax investigations and disputes.
Michael Sherry
Michael Sherry
Tax Barrister and Former Head of Chambers at Temple Tax
Bill Stevenson
Bill Stevenson
COP9 & Serious Tax Investigation Specialist at reasonable fees*
Rebecca Busfield CTA, MA Oxon
Rebecca Busfield CTA, MA Oxon
Chartered Tax Adviser with Big Four training, specialising in HMRC investigations for 20+ years including COP9/CDF, COP8, WDF, FTC, Let Property, compliance checks & disclosures.
Ingrid Blau
Ingrid Blau
Tax Investigation Specialist COP 8 & 9, Compliance checks, WDF, Voluntary disclosures, CJRS issues. Offshore matters including IHT & trusts and Crypto currency.
Charles Tateson
Charles Tateson
A fully qualified ex-HMRC Senior Tax Professional, having worked on the most serious & complex tax issues from both sides, I am uniquely placed to assist in these matters.
Jeremy Johnson
Jeremy Johnson
Solving tax problems - COP9, COP8, POCA, HMRC enquiries, disclosures and settlements. Friendly, experienced and commercial advice.
Ryan Witter CTA FCCA MPAcc Cert Probate Cert BV
Ryan Witter CTA FCCA MPAcc Cert Probate Cert BV
Paul Malin
Paul Malin
Taking the stress away from a tax investigation and giving back certainty. From Disclosure through to Settlement. Resolving any exit from EBTs, Remuneration Trusts etc.
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Tax Accountants

The following tax accountants are all willing to assist with simpler questions on this topic and to help you complete tax returns. Their profiles include contact details and other key information.

 
 
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