COP8 or COP9 Tax Enquiry

Received a COP8 or COP9 tax enquiry letter from HMRC?

Help is at hand…   


Serious tax investigations are dealt with by HMRC’s Fraud Investigation Service and this would include COP8 or COP9 tax enquiries. 

HMRC’s desire to tackle persistent tax avoidance means that the number of COP8 and COP9 enquiries launched by HMRC has increased significantly.  

HMRC have more information available to them now than ever before.   They receive vast amounts of information and data from third parties both here in the UK and overseas. 

Did you know that HMRC have automatic exchange of information agreements with overseas Governments? 

They also have their own surveillance software and share data with letting agents and online agents such as Airbnb or similar. 

HMRC also receive tip offs from the general public.  All of this data exchange has, inevitably, resulted in an increase in the number of COP8 and COP9 enquiries being opened. 

COP8 and COP9 Tax

Why might HMRC issue a COP8 or COP9 enquiry? 

COP8 is used when HMRC believe that you may have taken part in a tax avoidance arrangement which means that you have paid less tax than they believe is due.  It is not issued in the case where they believe tax fraud taken place, HMRC simply suspect that not all the tax due has been paid.  

COP9 is used by HMRC when they suspect that tax fraud has occurred.  HMRC’s specialist tax investigators will offer the taxpayer the chance to correct all their tax matters through the submission of a report called the Contractual Disclosure Facility.  

HMRC will typically look at the following areas of tax if they suspect “aggressive tax planning” might have been used: 

Income planning (loans instead of income) 

Film partnership schemes 

SDLP (Stamp Duty Land Tax Planning) 

Trusts (used for IHT tax planning); and

EBTs, Employee Benefit Trusts 

One thing is certain, if you have received a COP8 or COP9 notification letter from HMRC you will need specialist tax advice and professional help.  Failure to seek professional help from the beginning, could be costly in the end. We have a tax team ready and willing to help, every step of the way.    

If you would like to speak to a member of our specialist tax enquiry team contact us or telephone us on 020 7870 9050.  Or you can visit our web chat in the bottom right corner which is manned during office hours and you can leave a message out of hours. 

The RPGCC team are always just a click or call away.


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