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COP8 Taxby AMS Group
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HMRC Code of Practice 8

You've received a COP8 letter. Here's what to do in the next 48 hours.

Stay calm. COP8 is a civil investigation. But don't call or write to HMRC until you've taken specialist advice.

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Nick Davies

Led by Nick Davies — ex-HMRC, 40+ years in tax disputes

  • 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.

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Tell us when to call

We'll call you within 2 hours

Outside office hours? We'll call you by 11am the next working day.

We'll only call this number, and we won't mention HMRC in any voicemail or message.

Everything you tell us is treated in strict confidence, subject to our legal and regulatory obligations.

In the next 48 hours

Do this. Not that.

Small choices in the first two days are the ones most likely to be regretted later.

Do

  • Note the deadline in the letter and tell us immediately.
  • Keep every record, including computer records. HMRC's Code asks you to.
  • Keep filing your returns and paying on time. HMRC treats ongoing compliance as a sign of willingness to engage.
  • Gather the letter, recent returns and details of any schemes or structures used.

Don't

  • Call HMRC to “just explain” before you have advice.
  • Guess at answers. HMRC's Code warns that knowingly false statements can lead to criminal investigation.
  • Move, sell or transfer assets without advice.
  • Rely on the adviser who set up the arrangement HMRC is questioning. They may have a conflict of interest.

Before you reply

What HMRC already knows

HMRC can gather information before it writes, including from third parties. It also monitors open-source material such as Companies House, the Land Registry, news sites and public social media.

  • Third parties, such as banks and overseas tax authorities
  • Companies House
  • The Land Registry
  • News sites
  • Public social media

Assume HMRC knows more than the letter says.

The letter describes how HMRC wants to proceed, not everything it holds. That is one reason a first reply should be drafted by someone who has handled these investigations before.

Check your risk in 2 minutes

Your first week

What we do in your first week

Five steps, in order, from the first conversation to a reply that is on time.

    1

    Free, confidential call to understand your situation

    Tell us what the letter says. We will explain, in plain English, what HMRC appears to be looking at.

    2

    Review the letter and your records

    We check the issues HMRC has named, the years in scope and the deadline it has set.

    3

    Become your authorised agent and take over HMRC contact

    From that point, HMRC's calls and letters come to us rather than to you.

    4

    Set the strategy, including how best to engage with HMRC

    We agree with you how and when your full position is presented to HMRC, and explain what each option means for you.

    5

    Respond to HMRC within its deadline

    Your reply is made in the form that best protects your position.

See the whole process →

Who handles your case

COP8 casework only

Nick Davies, Head of Tax Disputes

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

Just received the letter

Five questions people ask us

A Code of Practice 8 investigation is civil, which means HMRC is not pursuing it with a view to criminal prosecution. That can change if HMRC comes to suspect fraud, so the way the early stages are handled matters.

No. Attendance at the meeting HMRC invites you to is voluntary. A well-prepared meeting can help, but you should take advice before deciding whether to go and what to say there.

Take specialist advice so that your full position is presented to HMRC completely and accurately. We help you understand the information requested and prepare a response within the deadline.

Your first call is free. If you want us to act, we start with a fixed-fee case review of £1,950 + VAT. We read the letter and your records, set out the risks and agree a strategy with you. You then receive a formal written quote for the next stages, with a fixed fee for each one, 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.

Yes. Once you appoint us as your authorised agent, HMRC's correspondence and calls are directed to us.
All questions →

Confidential consultation

Don't reply to HMRC until you've spoken to a specialist

Tell us what the letter says and we will talk you through your options, in confidence and without obligation.

Book a confidential call0161 850 2632

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.
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