For advisers
Refer your COP8 client to a specialist
FIS investigations need specialist handling. We work alongside you and hand your client back when the case is resolved.
Our referral promise
Referring a client is a judgement about who is best placed to handle the investigation. Here is how we keep that relationship intact. We handle COP8 investigations end to end. In the rare case where legal privilege becomes important, we’ll tell you early and can bring in a solicitor.
We don't take over your client's other work
Accounts, bookkeeping, self-assessment returns, payroll — that stays with you. We act only on the investigation, and we tell the client so in writing.
You stay informed throughout
You are copied on correspondence and told what is happening as the case moves, unless your client asks us to deal with them directly.
We'll call you within 2 hours
Outside office hours? We'll call you by 11am the next working day.
When to refer
Any of these is worth a conversation, even where you are already handling the matter.
A COP8 or COP9 letter has arrived
COP8 is HMRC's civil investigation procedure; COP9 is the one it uses where it suspects fraud. Either way, the clock starts the day the letter lands.
An enquiry has been taken over by FIS
FIS is HMRC's Fraud Investigation Service. When a case moves from a local tax office to FIS, the tone and the powers available usually change with it.
A Schedule 36 notice has been served
A statutory notice requiring documents or information to be produced. Missing it carries penalties, and the wording decides how much you have to hand over.
A client has used a scheme or holds offshore assets
Avoidance arrangements, trusts, overseas accounts and companies are where FIS increasingly concentrates, often years after the event.
Why independent handling protects you
Since 1 April 2026, HMRC has had stronger powers to act against advisers who deliberately facilitate non-compliance. Advisers acting in good faith are not the target. But where an investigation touches on advice your firm gave, it helps everyone if someone independent handles the HMRC side. Your client gets a specialist who deals with FIS every day, and you keep the relationship without being put in a conflicted position. We set out in writing where our role ends and yours begins before we act.
How referral works
- 1
You call or send the form
- 2
We'll call you within 2 hours
- 3
We agree scope with you and your client in writing
- 4
We hand the client back when the case closes
Send a referral
Tell us what has arrived and when. We will not contact your client without your agreement.
Partner pack
A short guide for your practice: how COP8 works, when to refer, and how we work alongside you. Tell us where to send it.
Briefings for practices
We run short CPD-style briefings for accountancy and law firms on COP8, COP9 and HMRC’s new adviser sanctions regime.