“A fair COP?” by Amit Puri, lead of Lancaster Knox’s Tax Investigations & Disputes practice

Amit Puri shares the latest Codes of Practice 8 and 9 tax investigations statistics, including 2021-22 figures straight from HMRC, and shares his insights on what they mean.


As previously outlined in my original article in 2019 and subsequent updates in 2020 and 2021, HMRC investigations carried out under their Codes of Practice 8 and 9 are intensive and resource hungry.


Without careful and experienced handling a client’s interests cannot be fully protected and the processes managed with more certainty. HMRC are looking for lost taxes, interest for the late payment of those taxes, and typically large penalties for failing to submit correct tax returns or failing to notify HMRC that taxes were payable. In addition to this, HMRC will usually seek to name and shame clients publicly – their non-financial weapon.


With this in mind, my focus returned to the statistics for HMRC’s serious civil tax investigations, specifically those cases under Code of Practice 9 (COP9) and Code of Practice 8 (COP8).

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