SI Code of Practice 8 (COP8) in Burton upon Trent
Special Investigations (SI) is a specialist group of offices within HMRC which have the task of investigating the most serious cases of
tax fraud and tax evasion . They also have responsibility for investigating cases of tax avoidance' under Code of Practice 8 (COP8).
Special Investigations is HMRC's most senior, and generally experienced, investigating body, and only becomes involved where there may be, in its view, a substantial amount of tax, or a serious issue involved. Dealing with a Special Investigations enquiry requires specialist professional advice and careful handling, if your interests are to be properly protected.
SI may investigate any arrangements where HMRC believes that tax may have been inappropriately avoided, as a result of tax planning arrangements which it considers contrary to its interpretation of the law. Where it does so Code of Practice 8 (COP8) is issued.
Such enquiries are not restricted to the review of any planned avoidance' transactions, but they can often arise in other circumstances such as when a person's residence in the UK, or the tax implications of interests held in foreign entities is being questioned.
The potential range of enquiries undertaken by SI under COP8 is almost unlimited and may be undertaken by SI where there is no allegation or suspicion of fraud but where there is a suspicion of tax loss.
Enquiries under COP8, by their very nature, can be difficult, complex and are often contentious. Such investigations usually involve significant sums of tax either on an individual case by case basis or by reference to a large number of cases sharing the same planning arrangements. Whichever way these investigations are viewed they are serious and should be handled by practitioners who have significant experience of dealing with such matters at this level.
HMRC and Investigations
HMRC is increasingly concentrating resources on tackling avoidance particularly involving offshore arrangements, misuse of pension schemes, offshore umbrella arrangements and corporate avoidance. Their actions can include raids and taking criminal prosecution action where it considers that avoidance activities may demonstrate deliberate misrepresentation of facts or falsification of documents.
As with any HMRC civil investigation there can be major financial benefits in properly handling the disclosure of information and documentation to secure the maximum mitigation of any penalties.
Contact Us Today
We have a wealth of experience in assisting clients in dealing with enquiries carried out by SI. If you would like to discuss how we might be able to help you, or to arrange an initial meeting on a no cost/no obligation basis, please contact us by telephoning
or email us using our 01283 761 777 Email Enquiry Form.