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

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.
Bill Stevenson
Bill Stevenson
COP9 & Serious Tax Investigation Specialist at reasonable fees* - Having been responsible for setting up the COP9 (Contractual Disclosure Facility) teams
Michael Sherry
Michael Sherry
Tax Barrister and Former Head of Chambers at Temple Tax
Charles Tateson
Charles Tateson
A fully qualified ex-HMRC Senior Tax Professional, having worked the most serious & complex tax matters from both sides, I am uniquely placed to assist in these matters.
Mark Taylor
Mark Taylor
Head of Buzzacott's award-winning Tax Investigations and Dispute Resolution team, bringing a unique understanding of the inner workings of HMRC to the advantage of my clients.
Rebecca Busfield CTA, MA Oxon
Rebecca Busfield CTA, MA Oxon
Chartered Tax Adviser with Big Four background, specialising in HMRC investigations for nearly 20 years including COP9/CDF, COP8, WDF, RTC, compliance checks & disclosures.
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.
Jacqui Fleming
Jacqui Fleming
Specialist in Tax Investigations/CoP9/Contractual Disclosure Facility /Compliance checks/Tax Enquiries/Voluntary Disclosures/Proceeds of Crime and criminal Investigations
Hirsch Sharma
Hirsch Sharma
We can sort all your tax vat etc problems with HMRC as we have done for many accountants and business clients. We can deal with TAX/VAT/PAYE investigations and penalties.
Ingrid Blau
Ingrid Blau
Tax Investigation Specialist COP 8 & 9, Compliance checks, WDF, Voluntary disclosures, CJRS issues. Offshore matters including Crypto currency.
Anton Lane
Anton Lane
I specialise in solving tax problems: HMRC enquiries, fraud investigations, or structuring your affairs efficiently to not attract HMRC scrutiny.
Richard Alderson
Richard Alderson
Now an experienced tax consultant, I have worked for over 30 years in HMRC and a Big 4 firm assisting clients and tax professionals to resolve tax disputes and manage tax risk.
Doug Sinclair
Doug Sinclair
A former HMRC Inspector with over 30 years experience in the tax investigation arena. Specialist in COP9 and Tribunal work.
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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.

 
Mark Rubinson
Mark Rubinson
 
 
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