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

Jacqui Fleming
Jacqui Fleming
Specialist in Tax Investigations/CoP9/Contractual Disclosure Facility /Compliance checks/Tax Enquiries/Voluntary Disclosures/Proceeds of Crime and criminal Investigations
Doug Sinclair
Doug Sinclair
A former HMRC Inspector with over 30 years experience in the tax investigation arena. Specialist in COP9 and Tribunal work.
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.
Bill Stevenson
Bill Stevenson
COP9 & Serious Tax Investigation Specialist - Having been responsible for setting up the COP9 (Contractual Disclosure Facility) teams for Scotland, Wales and NI.
Rebecca Busfield CTA, MA Oxon
Rebecca Busfield
I am an HMRC dispute and investigation specialist. I help clients deal with complex tax investigations, compliance checks or make voluntary disclosures.
Michael Sherry
Michael Sherry
Tax Barrister and Former Head of Chambers at Temple Tax
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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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