EXHIBIT 8.2

                                           ALLEN & OVERY LLP
                                           One New Change
Permanent Financing (No.8) PLC             London  EC4M 9QQ  United Kingdom
Blackwell House
Guildhall Yard                             Tel               +44 (0)20 7330 3000
London                                     Fax               +44 (0)20 7330 9999
EC2V 5AE                                   Direct            +44 (0)20 7330 3692



Our ref               MRK/ZKH/33775-00206 TX:213267.1

7th June, 2005

Ladies and Gentlemen

PERMANENT FINANCING (NO. 8) PLC - REGISTRATION STATEMENT ON FORM S-11

We have acted as United Kingdom tax counsel to Permanent Financing (No. 8) PLC,
a public limited company incorporated under the laws of England and Wales (the
ISSUER), in connection with the preparation of the registration statement on
Form S-11 (the REGISTRATION STATEMENT) to be filed with the Securities and
Exchange Commission (the COMMISSION) under the Securities Act of 1933, as
amended (the ACT), on 7th June, 2005, as amended on the date hereof, of which
the prospectus (the PROSPECTUS) forms a part. The Registration Statement and
Prospectus relate to the Issuer's issuance of the series 1 issuer notes and
series 2 issuer notes (the US NOTES).

As United Kingdom tax counsel, we have advised the Issuer with respect to
certain United Kingdom tax consequences of the proposed issuance of the US
Notes. This advice is summarised under the headings "Summary of prospectus -
United Kingdom tax status" and "United Kingdom taxation" (collectively, the
DISCUSSIONS) in the prospectus relating to the US Notes which is part of the
Registration Statement. We hereby confirm that the opinions set forth in the
Discussions represent our opinions as to the matters of law covered by them.

We hereby consent to the filing of this letter as an exhibit to the Registration
Statement. We are aware that we are referred to in the Discussions and under the
heading "Legal matters" in the Prospectus, and we hereby consent to the
references to us in those sections without thereby implying or admitting that we
are "experts" within the meaning of the Act or the rules and regulations of the
Commission issued thereunder, with respect to any part of the Registration
Statement, including this exhibit.

Yours faithfully,

/s/ Allen & Overy LLP

ALLEN & OVERY LLP



Allen & Overy LLP is a limited liability partnership registered in England and
Wales with registered number OC306763. It is regulated by the Law Society of
England and Wales. The term partner is used to refer to a member of Allen &
Overy LLP or an employee or consultant with equivalent standing and
qualifications. A list of the members of Allen & Overy LLP and of the
non-members who are designated as partners is open to inspection at its
registered office, One New Change, London EC4M 9QQ.

Allen & Overy LLP or an affiliated undertaking has an office in each of:
Amsterdam, Antwerp, Bangkok, Beijing, Bratislava, Brussels, Budapest, Dubai,
Frankfurt, Hamburg, Hong Kong, London, Luxembourg, Madrid, Milan, Moscow, New
York, Paris, Prague, Rome, Shanghai, Singapore, Tokyo, Turin and Warsaw.