A7.422 Steps in the investigatory procedure under COP8

Administration and compliance

A7.422 Steps in the investigatory procedure under COP8

A7.422 Steps in the investigatory procedure under COP8

Once a case has been classified as an avoidance cases which requires an investigative approach (see A7.420), the Fraud Investigation Service will register it as a Code 8 case. The case will then go through the following process:


    •     the case will be formally opened and notification will be given to the taxpayer


    •     an opening meeting will be arranged between the FIS officers and the taxpayer


    •     the case will be progressed with further correspondence or meetings or visits


    •     a payment on account may be requested from the taxpayer


    •     the investigation will be drawn to a conclusion which is likely to include a financial settlement and the signing of a certificate of full disclosure

Opening of the COP8 case

Once a case is registered as Code 8 case the taxpayer will be notified. Where earlier contact has been made by telephone, a letter should always confirm this1.

The investigator should make it clear that the investigation is to be undertaken by FIS and a copy of Code of Practice 8 should be enclosed. Tax agents will be notified where appropriate. Where any open self assessment enquiries are to be included in the FIS Code 8 Investigation the wording of the notification letter should make it clear that is the case. Where there is a current self assessment return with no existing enquiry, the notice to investigate the taxpayers affairs will normally incorporate the written notice of enquiry required by Section 9A(1)

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