Investigations under Code of Practice 8 are launched where HM Revenue & Customs have reason to believe that there is a risk of significant losses of tax due to an intricate tax avoidance scheme, or schemes, perhaps involving offshore complexities.

Such schemes or transactions may include:

unapproved share schemes;
contrived remuneration arrangements;
use of non-domiciled individuals with assets based in the UK;
issues of status (self-employed or employee);
secondment of employees to or from overseas;
pension schemes;
transfer of assets overseas;
use of offshore accounts.

Although tax fraud is not suspected at the outset, this type of investigation is triggered where more unusual transaction structures precipitate large tax savings.

If, however, HM Inspector of Taxes has reason to suspect tax fraud as a result of his findings, then the investigation will be further pursued under Code of Practice 9 (2005).

Should you have any further queries regarding Civil Investigations of Fraud, please contact us on solutions@morrispalmer.co.uk or call 01403 750 444.