An investigation by HMRC can be very disruptive and expensive: that's why we strive to resolve matters quickly and secure the best results for individuals and businesses. We successfully resolve disputes day in and day out because we know how the taxman thinks.
Our team of tax investigation specialists understand the stress and anxiety HMRC interventions can cause. Winners of 'Best Tax Investigations Team' at the prestigious 2009 Taxation Awards, our team has spent years working at either a senior level within HMRC or settling enquiries with tax authorities.
Understanding the tax inspector allows us to predict HMRC’s actions and respond to them effectively. Our expertise allows us to develop a strategy to maintain control of an enquiry and shape the most cost-effective outcome for you. We tailor our services to meet your unique needs and can tackle all types of investigations or enquiries, including those under the Contractual Disclosure Facility (CDF). We can handle the investigation for you directly or provide specialist support to your other advisers, including your legal team.
Hot topics in tax investigations
HMRC encourage voluntary disclosures
HMRC is responsible for ensuring that taxpayers comply with tax legislation but has recently shown an increased focus in ensuring everyone complies. HMRC officers are tasked with identifying and tackling individuals, partnerships and companies who receive income or gains but do not currently file returns, and those who file inaccurate or incomplete returns. Through the increased use of ‘clever technology’, HMRC investigations are becoming better-targeted and more effective.
If you have a voluntary disclosure to make, our Tax Risk and Investigation Management team can help you to secure the best possible outcome. Our team members use their experience and skills to identify at the outset how an approach to HMRC can best be made. Through years of experience in successful negotiations with HMRC, we understand what scope there is to settle cases. This can have a significant effect on the amount of any penalty and the number of years for which HMRC will seek to collect tax. To speak to someone confidentially, call our helpline on 0800 032 8374.
Contractual Disclosure Facility
HMRC carries out investigations where they suspect tax fraud under Code of Practice 9 (COP9). Under this Code HMRC offer a taxpayer the opportunity to make a full disclosure under a contractual arrangement, called the Contractual Disclosure Facility (“CDF”) - read more here.
Liechtenstein Disclosure Facility
The Liechtenstein Disclosure Facility (LDF) was introduced in 2009 following an agreement between the Government of Liechtenstein and HMRC. Since the original Memorandum of Understanding was signed in August 2009 there have been three joint declarations published which clarify and add to the terms of the original Memorandum of Understanding.
Such has been the success of the LDF since it was first announced that the deadline for making a disclosure under the LDF was extended to 5 April 2016. Read further information about the facility and the opportunities it offers.
The UK-Swiss Tax Cooperation Agreement came into force on 1 January 2013 and the first tax payment in respect of undisclosed tax liabilities for earlier years was made on 31 May 2013. Please click here for further information.
HMRC continues to investigate HSBC Swiss account holders using Code of Practice 9 (COP9) / Contractual Disclosure Facility. Traditionally such investigations have only been used where HMRC is virtually certain that a disclosure of irregularities will be made. However, it seems that HMRC is now prepared to use COP9 in more speculative circumstances and to ensure that such account holders cannot take advantage of the Liechtenstein Disclosure Facility
Agreements with Crown Dependencies
In February 2013 HMRC entered into a disclosure arrangement with the Government of the Isle of Man. Similar agreements have subsequently been reached with the Governments of Guernsey and Jersey. HMRC is also looking to enter into equivalent agreements with other Crown Dependencies. Read more on the Crown Dependencies.
HMRC taskforces and initiatives
HMRC has announced a number of initiatives to close the “tax gap”. To find out more and see whether your sector is one of those affected, see our HMRC taskforces and initiatives page.
VAT and property transactions
HMRC often contacts the vendors and purchasers of property for further information about the transaction, in order to find out what direct and indirect tax has been paid. Read more about VAT and property transactions.
Alternative Dispute Resolution
If you have a dispute with HMRC that you have been unable to settle through negotiation, you may wish to consider using Alternative Dispute Resolution (ADR) rather than taking an appeal to the tax tribunal. Under ADR, facilitators seek to help HMRC and the taxpayer reach a negotiated solution. Read more.
Meet the team
We have a Tax Investigations representative in all our office locations, closely supported by a panel of dedicated specialists. Our experts are mainly ex-HMRC investigators and inspectors who understand the HMRC mindset and have used their skills for many years to achieve the best results for clients.
Meet the TRIM Panel