Tax Investigations
HMRC on your case? We’re your best defence when it comes to navigating tax investigations and disputes. We act fast, protects your position and drives the best possible outcome. Always discreet. Always confident.
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When HMRC Gets Involved, Pressure Builds Fast
An HMRC enquiry disrupts everything. It arrives without warning. Demanding time you can’t spare. Creating uncertainty that unsettles leadership, investors and your wider team.
You’ll worry about how serious the issue is. What the implications are. How long it’ll drag on and what HMRC is really looking for. Every request feels urgent. Every detail feels risky.
There’s also the personal pressure. The fear of penalties. The concern something has been missed. The sense that you are already on the back foot.
This is exactly when experienced support matters. A team that knows HMRC inside out and can restore control, clarity and calm from day one.
Resolve Your Tax Investigation
OUR APPROACH
Minimise tax, interest and penalties
Close enquiries
Reduce future risk
A TEAM THAT’S BEEN ON BOTH SIDES OF THE TABLE
You get a focused team with HMRC and Big 4 backgrounds.
We understand how investigations impact reputation, investors and live transactions. Protecting all of that is our priority.
When you work with us, you get more than technical expertise. You get a team that has lived and breathed HMRC investigations from every angle. Our people are highly experienced practitioners, all HMRC trained, with a proven track record of resolving disputes and securing fair, efficient settlements.
And behind them sits the full weight of Cooper Parry’s tax specialists, ready to support on complex issues whenever the case demands it.
Get Help With a Tax Investigation
We support clients through every type of HMRC enquiry. From routine checks to complex fraud investigations, multi‑year disputes and full voluntary disclosures.
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Code of Practice 9 – investigations into suspected serious fraud:
- Investigations under Code of Practice 9; acceptance of the offer of the Contractual Disclosure Facility (CDF) and COP9 denials
- Unprompted disclosures under the Contractual Disclosure Facility for deliberate tax understatements
- COP8 – Complex civil investigations where tax fraud is not suspected. Cases with no allegation of fraud, but significant technical issues. We challenge HMRC’s position, narrow the issues and drive resolution efficiently
- Assistance with criminal investigations
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Routine checks into filed returns, including:
- Enquiries into personal tax returns
- Other non-statutory interventions, e.g. nudge letters and ‘discovery enquiries’
- IHT enquiries
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Helping you put historic issues right through structured, recognised HMRC disclosure routes:
- Contractual Disclosure Facility (CDF) for deliberate tax understatement
- Digital Disclosure Service for onshore irregularities
- Worldwide Disclosure Facility for offshore issues
- Failure to Notify disclosures, including those for ‘hidden economy’ activity
- Leverage projects, such as the “One to Many” nudge letters
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When it comes to business taxes, HMRC will carry our investigations ranging from queries about single items of expenditure on a tax return to multi-year enquires covering all heads of duty, looking into:
- Corporation Tax enquiries
- Partnership enquiries
- Cross-Tax enquiries
- Employer compliance checks into PAYE, P11Ds and PSAs
- VAT compliance checks
- Supply chain investigations
- Customs Duty inspections
- Employment status enquiries, managed service companies, personal service companies and “IR35”.
- Tax return enquiries for self-employed individuals
- Other non-statutory interventions
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Assistance with HMRC enquiries undertaken by HMRC’s Counter Avoidance teams:
- EBTs
- EFRBS
- Other marketed avoidance schemes
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Support when enquiries escalate or become contentious, including:
- Discovery and assessments
- Information notices
- Penalties
- Closure notices and appeals
- Alternative Dispute Resolution (ADR)
- Tax litigation advice
- Full tax tribunal support
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Other matters concerning your relationship with HMRC, such as:
- Time-to-pay arrangements
- Corporate Criminal Offence guidance
- Interest disputes
- Special Relief
Let’s talk today
Want us to call you? Let’s start a conversation!
Get in touch with Nathan Ross-Sercombe
FAQS
Simple enquiries can finish in a few months. More complex or multi‑year cases can run for a year or longer. With the right strategy and clear communication, we help keep the process efficient and avoid unnecessary delays.
HMRC can assess tax for the last 4 years for genuine mistakes, 6 years for careless errors and up to 20 years for deliberate behaviour or where there has been a failure to notify. In essence, how far HMRC can go back depends on the circumstances in which the irregularities occurred.
HMRC uses shared government and local authority information, third party information, information obtained through mutual international exchange and ‘opensource’ information (that which is already in the public such as social media) in conjunction with tax return data and specialist software to identify and connect risks. Where fraud is suspected from the outset, cases are opened either by HMRC’s Fraud Investigation Service or in very serious cases, by their Criminal Investigations teams.
Common triggers include inconsistencies in returns. Large swings in income or expenses, missing information, data mismatches, industry norms not being met. Sometimes it only takes one anomaly. HMRC also run campaigns where they believe there are specific risks within certain industries or taxpayer groups. Receiving an enquiry does not always mean that HMRC think you have done something wrong, but with the shift to a data-driven approach most enquires are driven by quantifiable and specific risks.
COP9, short for Code of Practice 9 is HMRC’s process for cases where it suspects serious tax fraud has taken place. Tax fraud in this context mean that tax has been underpaid knowingly. When a case is selected for investigation under COP9, HMRC offers an individual the opportunity to make a full disclosure through the Contractual Disclosure Facility. In return, HMRC agrees not to pursue criminal prosecution unless the disclosure is found to be false or incomplete.
The CDF is HMRC’s formal process for disclosure of tax irregularities in cases where an investigation has been open due to a suspected serious tax fraud or where an individual who is not presently being investigated under COP9 wishes make a disclosure of underpaid tax due to deliberate behaviour. Entering into CDF gives you the opportunity to admit any deliberate behaviour, make a full disclosure and avoid criminal prosecution. In return, you agree to cooperate fully and provide a complete account of what happened. There are a limited number of scenarios where CDF is not available and this includes cases where you are already under Criminal Investigation or where HMRC is already considering Criminal Investigation.
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