HMRC Code of Practice 8 specialists
Received a COP8 letter from HMRC?
A Code of Practice 8 investigation is civil, not criminal. But what you say and sign in the next few weeks can decide how it ends. Speak to a specialist before you reply to HMRC.
Led by Nick Davies — ex-HMRC, 40+ years in tax disputes
Or call 0161 850 2632
- Strictly confidential
- Specialists in HMRC FIS investigations
- We'll call you within 2 hoursOutside office hours? We'll call you by 11am the next working day.
Who leads our tax disputes team
Nick Davies
Head of Tax Disputes, AMS Group
“I started my career at HMRC and have spent over 40 years representing clients in tax disputes. Every COP8 case we take on is handled by our specialist tax disputes team.”
It's a civil investigation.
HMRC's Code says COP8 is not undertaken with a view to criminal prosecution.
You have rights.
Co-operation is voluntary, but HMRC can use formal powers if you don't co-operate, and co-operation is what earns penalty reductions. You can bring an adviser to every meeting, and you don't have to sign HMRC's meeting notes.
It can be resolved.
HMRC aims to reach an agreed settlement. Penalties can be reduced for co-operation and disclosure.
Why this matters
Why a COP8 investigation must be handled carefully
COP8 cases are run by HMRC's Fraud Investigation Service, whose officers are highly trained and well resourced.
HMRC can switch to a COP9 fraud investigation, or a criminal one, if it suspects fraud at any point.
HMRC usually has information before it writes: from banks, overseas tax authorities, Companies House, the Land Registry and social media.
The investigation often widens beyond the issues raised in the first letter.
- 814
- COP8 investigations open at HMRC as at 31 March 2026
- 191
- new COP8 cases opened in 2025–26. This is specialist work most accountants never see.
- Up to 200%
- maximum penalty in the most serious offshore cases involving deliberate behaviour
Source: HMRC Fraud Investigation Service technical note, 2025 to 2026.
What happens next
How a COP8 investigation unfolds
- 1
The opening letter
HMRC says it is investigating under COP8 and names the issues.
- 2
The opening meeting
HMRC invites you to explain the facts. Preparation is critical.
- 3
Information requests
HMRC asks for documents and can issue formal notices to you and third parties.
- 4
Payment on account
HMRC may ask you to pay towards the tax it thinks is due.
- 5
Negotiation
Tax, interest and penalties are calculated and argued.
- 6
Settlement
Agreement, and possibly a Certificate of Full Disclosure.
How we help
How we protect you
Immediate case review
We read the letter, assess the risks and set the strategy within days.
Taking over HMRC contact
All correspondence and calls go through us.
Meeting preparation and attendance
We prepare you thoroughly and sit beside you.
Information requests
We check what HMRC is entitled to and challenge requests that go too far.
Penalty negotiation
We argue behaviour, disclosure quality and time limits to reduce what you pay.
Settlement and beyond
We review any certificate before you sign and help you stay compliant.
Discreet by default
- We won't leave voicemails unless you tell us we can.
- We can call from a withheld number if you prefer.
- Letters come in plain envelopes.
- Meet us at any of our 17 UK offices, away from your home or workplace.
Not sure how serious your situation is?
Answer 6 quick questions and get an instant, confidential indication of your risk level.
Take the 2-minute COP8 risk checkCredibility
Why clients and advisers choose us
Nick Davies
Head of Tax Disputes, AMS Group
Began his career at HMRC
Over 40 years advising and representing clients in tax disputes
Founding member of the Contentious Tax Group; represents clients at the Tax Tribunal
ICAEW Chartered Accountants
COP8 or COP9?
Know which investigation you're facing
COP8
- Civil investigation
- HMRC suspects significant tax loss, often from avoidance or complex arrangements
- Fraud is not usually alleged at the outset
COP9
- HMRC suspects fraud
- You're offered the Contractual Disclosure Facility
- Protection from criminal investigation for a full and honest disclosure
FAQ
Common questions
What it costs
- 1
Free first call
No cost, no obligation.
- 2
Case review
£1,950 + VAT
We read the letter and your records, set out the risks and agree a strategy with you.
- 3
Fixed fee for each stage
You receive a formal written quote before any further work begins.
- The case review fee is credited in full against the first stage if you instruct us.
- If HMRC widens the investigation, we agree a revised fee with you before doing the extra work.
Confidential consultation
Don't face HMRC alone
The earlier you get specialist advice, the more options you have. Your first conversation is free and strictly confidential.
Free first call. Fixed-fee case review from £1,950 + VAT, credited against your first stage.
Not ready to talk? Take the 2-minute COP8 risk check
- ICAEW Chartered Accountants
- Strictly confidential
- Specialist in HMRC investigations
- We'll call you within 2 hoursOutside office hours? We'll call you by 11am the next working day.