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Tax Investigations

"Superb understanding of what matters and when in regulatory investigations." — Legal 500 2024 


HMRC investigations – whether civil or criminal - into your tax affairs are intimidating, stressful, time consuming and costly. Our experience is it important to get the right advice as soon as possible to have a better experience and achieve the best possible outcome.

Many tax investigations for alleged non-payment of tax can be settled ‘civilly’ through HMRC disclosure facilities although HMRC (through the CPS) do criminally prosecute both big and small cases. HMRC are not to be under-estimated.

HMRC want to recoup the Government’s emergency funding for financial support that has been wrongfully or fraudulently obtained through tax investigations and criminal prosecution.

If you are under or at risk of criminal investigation for tax fraud then you need advice from a specialist criminal lawyer – our legal advice will be confidential and privileged.

We will use our knowledge and experience to resolve the investigation and work in multi-disciplinary teams with forensic tax investigators and accountants (who are often ex HMRC tax inspectors) and tax barristers if necessary to bring your tax affairs up to date and negotiate a settlement.

Although HMRC prosecute tax fraud and related offences such as money laundering, they will often settle matters through their civil fraud investigation procedures under Code of Practice 9 where appropriate – which generally provides immunity or protection against prosecution in exchange for a full disclosure.

Refusing such an offer or making an incomplete disclosure will lead to higher penalties on any unpaid tax and could result in prosecution and if convicted a criminal record.

So, if you have received tax enquiry or investigation correspondence from HMRC or you are worried that you need to regulate your tax affairs then please get in touch with one of our team who are able to devise the best strategy to protect your interests.

Our Experience

  • Advised third party in relation to information requests connected to Danish Cum-Ex trading investigation.

  • Acted for commercial landlord of prosecuted by HMRC for fraud relating to non-declaration of capital gains and rental income.

  • Defending company directors accused of alleged tax credit fraud with temporary workforce. Clients were acquitted following trial.

  • Representing business man in retail food sector interviewed under caution by HMRC for allegedly submitting false VAT returns.

  • Represented a senior executive in a US based company in a complex tax investigation carried out by HMRC’s Fraud Investigation Service (Offshore Corporate & Wealthy) Team. No further action taken against client.

  • Represented a Director of UK company into alleged false accounting and tax related criminal offences.

  • Acted at hearings before the First-Tier tax tribunal in respect of indirect tax investigations and MTIC investigations.

  • Acted for accountancy firms served with compulsory information notices by HMRC relating to clients’ tax affairs.


We can discuss the funding options, the proposed scope of work and budget with you. Depending on the situation, you should check whether you have any legal expenses insurance (for example under professional indemnity, Directors’ & Officers’ or household insurance policies) or consider whether a third party, such as an employer, will contribute to your legal fees (eg under an indemnity).

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