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Code of Practice 8


Code of Practice 8 (COP8) is the basis on which HMRC’s Fraud Investigation Service (FIS) conduct an investigation where they suspect tax fraud or bespoke avoidance has been undertaken but they have decided not to open a Code of Practice 9 (COP9) enquiry.

If HMRC’s FIS team have opened COP8 enquiry on you or your client then it means that they believe the case is serious, complex and that the potential tax at stake is significant. Before issuing the COP8 notification letter, HMRC will have undertaken considerable work to verify the information that they hold.

If, during the course of their investigation, HMRC develop a suspicion that you/your client has been involved with serious tax fraud then they will seek to deal with the investigation under COP9 or, in some cases, will criminally prosecute.

It is vital that care is taken with a COP8 investigation as, unlike COP9, there is no guaranteed protection from prosecution.

HMRC will undertake their own investigation into your/your client’s tax affairs and will require access to a significant quantity of paperwork during the process. It is important that this process is properly managed as HMRC are within their rights to approach third parties for the information if the taxpayer does not provide it within what they would consider to be a reasonable time period. There is a clear reputational risk if HMRC write to your suppliers, customers, ex and/or current employers or banks.


If you or your client has received a COP8 notification letter from HMRC, it is important to seek professional advice before responding to ensure that HMRC do not obtain information they are not entitled to and that they do not visit your home and/or place of business without sufficient cause.

It is also important to be proactive as failure to engage with HMRC will be viewed as a wilful act of non-cooperation by the taxpayer, which can have significant penalty implications.

As part of the COP8 process, HMRC will usually expect to meet with you/your client face to face. We would strongly dissuade you from meeting with HMRC without specialist representation.


Hamilton Rose have 30 years of combined experience dealing with COP8 – we know how to manage the process correctly to ensure that HMRC do not obtain information they are not entitled to, that the correct amount of tax is paid and that your best interests and assets are protected.

We will ensure that you are fully supported throughout the process and give you peace of mind that any historic UK tax inaccuracies are fully resolved.