HMRC classify tax investigations as “serious” when the tax interest and penalties that they believe they will recover amounts to at least £75,000.

Such investigations are usually dealt with by Specialist Investigation (SI) units within HMRC.


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HMRC always reserve the right to prosecute in all tax evasion cases.  However they are often willing to proceed under their Code of Practice 9 (COP 9) investigation process. 

Under the COP 9 investigation process, HMRC will guarantee not to prosecute, and will offer the possibility of a Contract Disclosure Facility (CDF) which requires an Outline Disclosure to be made, followed by a detailed Disclosure Report.  HMRC’s offer will lapse after 60 days.  If you do not respond to their offer, or if you reject it then HMRC will carry out their investigation and may then prosecute.     

No investigation by HMRC should be treated lightly.  All investigations will cause anxiety and cost money to deal with even if little or no tax is payable at the end of the day.

Serious tax investigations can cover all taxes and duties including, income tax, corporation tax, capital gains tax (CGT), inheritance tax (IHT), national insurance, PAYE and VAT.      

The category of tax is irrelevant. 

What matters is the amount of tax.

HMRC was formed in April 2005 when HM Inland Revenue and HM Customs & Excise merged.

Since then HMRC have overhauled their approach to tax administration, collection and investigation.   

Some of the differences in HMRC’s approach since include:

Centralisation of operations
Specialist investigation units
Exchange of information with foreign tax authorities
Enhanced legislation
“Connect” system
Risk and intelligence sections
Private sector expertise
Targeted campaigns
PR and advertising  
Civil recovery action   
Criminal prosecutions

Since 2005 HMRC’s approach to tax evasion has hardened considerably and they are producing results. 

HMRC now use the press and social media to identify tax evaders and publicise their recovery action.  

If HMRC make contact with you about a serious matter then it almost certain that they have something on you.

Do not try and deal with any HMRC investigation by yourself.  You will need specialist help which we can provide.

Get in touch with us a matter of urgency and we will assess your case and deal with HMRC on your behalf.

We are on your side and we will protect your interests when dealing with HMRC.

Most people are aware of any “tax problem” that they may have but the reality is often that they are afraid to deal with the problem because they cannot see “a way out”. 

The “tax problem” could be something recent, or something lurking from the distant past.  Whatever it is – it needs dealing with.

It is always better to approach HMRC first rather than have them knocking on your door.  Again, don’t approach HMRC by yourself.  The disclosure needs to be properly assessed so that it is complete and maximises your opportunity to demonstrate to HMRC that you are serious about sorting the problem. 

If you need to disclose something to HMRC then make your mind up to do just that, and get in touch with us.  The penalties are significantly lower for “unprompted disclosure”.

Remember – we are on your side.

Let us help you.