Tax Investigations

For expert advice and assistance with all aspects of tax investigations and disputes, visit our new, dedicated tax investigations website.

Our approach to investigations

HM Revenue & Customs (HMRC) tax investigations can be intimidating and undermine your business and reputation. At worst, they can be a threat to your liberty. The modern regime at HMRC can seem abrasive and hard to manage. Although very serious cases are few in practice, the incidence is increasing as HMRC concentrates its focus on targeting and tackling tax evasion in all its forms (the yield from tax investigations now runs into billions of pounds and is growing each year).

By working with HMRC, and understanding the reasons for their enquiries, it is possible to exercise a level of control and reduce both the timescale and, consequently, the level of anxiety (something we never underestimate). Whilst we only act on the basis that a full and frank disclosure will be made, we will robustly defend our clients’ legitimate technical positions.

At the other end of the scale, there are times when local district level enquiries can cause particular problems, and we are certainly noticing a tendency for HMRC to take entrenched or unusual positions. We specialise in unblocking these situations – sometimes a fresh pair of eyes can see a way forward that is not obvious when you are closely involved. In between the tax districts, the Prosecution Office and Specialist Investigations Office is a host of other specialist departments that may raise investigative enquiries, including the anti-avoidance divisions and the Offshore Fraud Project Teams.

As part of HMRC Compliance Checks, effective from 1 April 2009, the operation of PAYE, National Insurance, VAT and other taxes are also under scrutiny and we have the experience to deal with these cases most effectively.

Services for clients and advisers

We act on behalf of clients that approach us for advice but many of our cases come from other advisers. This can be firms of accountants who either do not have the time or the resources to deal with such cases, or who are just seeking some assistance or a second opinion.

Our instructions also come from solicitors who have been approached by clients for advice or those clients who face the possibility of prosecution in serious cases. We are the adviser to the advisers!

We appreciate that every tax enquiry is different and we tailor our service to the individual circumstances of each investigation in order to provide the best possible scenario for our clients. With our extensive experience, it is likely that we have previously dealt with cases similar to yours. We deal with all types of investigations, no matter how large or small. In particular, we have extensive experience in the areas listed below.

• Cases of suspected serious tax fraud (Code of Practice 9).
• Enquiries into tax avoidance schemes and structures (Code of Practice 8).
• Investigations being conducted by HMRC’s Specialist Investigations or Civil Investigation of Fraud teams.
• Amnesties – NDO, LDF and THP.
• Offshore bank account enquiries.
• Offshore trust structure enquiries.
• Residence, ordinary residence and domicile enquiries.
• Local office and district enquiries into personal self-assessment or Corporation Tax returns.
• Voluntary tax disclosures.
• PAYE and NIC enquiries.
• Construction Industry Scheme enquiries.
• Status enquiries.
• Acting for executors of estates where there are assets within the estate that have not been subject to UK tax during the deceased’s lifetime.
• Personal service companies/IR35.
• Tax enquiries stemming from the Metropolitan Police Operation ‘Rize’ – safety deposit box holders.
• Tax litigation advice.
• Professional negligence cases.

If you would like further information on any of our tax investigation services, please telephone us on 07774 827879 or email our Tax Investigations Consultant.