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HMRC internal manual

Technical Teams Operational Guidance

HM Revenue & Customs
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Code of Practice 8 cases: identification of Code 8 cases: general

COP 8 applies to all investigations worked by Fraud Investigation Service (FIS) technical teams where the Contractual Disclosure Facility (CDF) COP 9 is not appropriate.

COP 8 is primarily used to investigate cases of avoidance, however there will occasionally be circumstances where FIS wish to investigate a case involving evasion but for various reasons the criteria for using COP 9 under the CDF procedure do not apply. In these circumstances COP 8 will be used instead.

Cases investigated using COP 8 will often attract a liability to penalties.

For more detailed information on the indicators of fraud see TTOG2120, and for tax avoidance see TTOG3435 and TTOG3440. For more information on assessing the likely tax at risk see TTOG2130.

If in any doubt as to the appropriate Code Of Practice, the case should be referred to the operational leader before the registration report is finalised. Your registration report must make it clear why you are proposing to use COP 8 rather than COP 9

There should be no occasion when the CDF procedure (TTOG10040) is applied in a COP 8 case.