There are some tax investigations that are more serious in their nature, either by virtue of the behaviour of the taxpayer or perhaps because of their relative magnitude to other tax issues.

These enquiries will be undertaken by HMRC’s Criminal Investigation Unit and can extend to investigation of suspected fraudulent behaviour. The investigations will often cover all of your personal and business tax affairs and are usually conducted in such a way as to examine every last detail. You would be expected to allow HMRC access to any records that might reasonably be required to assess your tax position. This can be a time consuming and difficult process.

We can make representation on your behalf about the nature of your case and to agree with them the amount of tax owed as a result of the alleged previous failing. This would usually take the form of a detailed report to be agreed by you and presented to HMRC.

We can also seek to negotiate with HMRC to explore if it is possible to deal with your case under the Civil Investigation of Fraud Procedures. This would mean that in exchange for a full and timely disclosure, HMRC will agree to cease any criminal proceedings against you, and instead pursue you under their civil powers. This removes the possibility of non-financial sanctions such as community service or even jail terms.

case study

We were engaged to act on behalf of an entrepreneur who had not filed tax returns for a number of years and as such had undisclosed income and gains that should have been declared to HMRC and tax paid thereon.  We approached HMRC and were able to obtain agreement that the matter would be dealt with under the civil investigation of fraud procedures.  Following our initial work, we compiled calculations of tax due and dealt with connected issues that would have resulted in further tax and have been able to agree a timescale over which the tax will be settled.

case study

We acted on behalf of a director who had deliberately omitted income from his VAT and Corporation Tax returns, following a serious downturn in his income.  We met with HMRC and disclosed the income and the tax that we believed to be payable.  We explained the background to our client’s omission and again agreed that criminal proceedings would not be used against our client.  We negotiated with HMRC on the matter of the penalty and managed to achieve a better result than the client had anticipated.


Tax disputes with HMRC are often an onerous and stressful matter to deal with. We are often engaged to assist taxpayers in managing the process from start to finish.

At the root of every tax dispute is either disagreement on the facts of a taxpayer’s situation, or the interpretation of the tax legislation that has been applied to assess the affairs of the taxpayer.

We are experienced in managing both aspects of this process and will continually be advising on the likely outcome and strategy employed in the handling of the case.

Whilst it is very often the case that reaching an agreement with HMRC is the best way to conclude such a matter, we are never afraid to disagree with HMRC. We have often made successful representations which were originally contrary to the interpretation of HMRC.

We always act in the best interest of our clients with a view to them paying only the right amount of tax and no more!

case study

We were engaged by a taxpayer who had failed to disclose property letting income from multiple properties over several tax years. We advised our client to disclose all the income to HMRC at his earliest opportunity and then agreed a system for calculating the tax due in a way that was fair but favourable to our client.   In view of our full and prompt disclosure, we were able to agree that penalties would be suspended and after two years of full compliance, the penalties were written off.

case study

We were engaged by a professional partnership to deal with an enquiry into entries made on their partnership tax return.  A review of the papers supplied by HMRC led us to identify that the inspector had acted beyond the powers prescribed to him by law. We made representations to the HMRC Inspector on behalf of the taxpayer following which the Inspector was forced to withdraw his enquiry and as a result, no additional tax was payable by the client.