Specialist UK tax advice for London individuals, landlords, directors and businesses

HMRC tax investigation accountant London

HMRC Tax Investigation support for serious enquiries, disclosures, penalties and settlement.

Tax Accountant London helps individuals, landlords, directors, companies, employers, contractors and internationally connected clients respond to HMRC tax investigations, serious compliance checks, COP8, COP9, offshore issues, business records reviews, VAT, PAYE and penalty disputes.

HMRC tax investigations COP8 and COP9 Tax disclosures Penalty behaviour review Settlement support
A tax investigation is different from a routine enquiry.

The response needs to be controlled from the start. We review the HMRC letter, tax years, records, behaviour risk, disclosure route, penalty exposure and whether the case may involve COP8, COP9, VAT, PAYE, offshore income or director/company tax issues.

01 Protect the first response

We review HMRC’s letter, powers, tax years, allegations and deadlines before records are sent.

02 Quantify the exposure

We review tax, interest, penalties, behaviour, disclosure route and possible settlement position.

03 Manage HMRC strategy

We prepare responses, disclosures, schedules, penalty arguments and HMRC correspondence.

HMRC investigation help

An HMRC tax investigation is a serious review of tax risk, behaviour and records.

A tax investigation can start from an HMRC compliance check, third-party data, offshore information, property records, VAT return differences, payroll records, company transactions, unusual tax return entries or suspected deliberate behaviour. It may cover one tax year or several years.

The key is to understand the type of investigation before responding. A routine records request, a formal enquiry, a COP8 investigation, a COP9 offer and a voluntary disclosure all need different handling.

Who needs HMRC tax investigation support

Support for individuals, landlords, companies, directors, employers and clients with offshore or complex tax issues.

Investigation work is not only about answering HMRC’s questions. It is about controlling scope, evidence, disclosure, behaviour classification, penalties and settlement.

01

Individuals and high earners

Self Assessment entries, foreign income, dividends, capital gains, unexplained deposits, tax charges and earlier-year corrections.

02

Landlords and property owners

Rental income, omitted years, Let Property Campaign, property expenses, mortgage interest, CGT and property disposal reporting.

03

Companies and directors

Corporation Tax, director loans, dividends, private expenses, company accounts, VAT, payroll and close company transactions.

04

Employers and VAT businesses

PAYE, P11D, CIS, employment status, VAT returns, input tax, sales VAT, late registration and employer compliance reviews.

HMRC investigation letter review

The investigation letter sets the tone, scope and risk level.

We start by reading the HMRC letter carefully. The wording may indicate whether HMRC is making a routine enquiry, using information powers, asking about specific risks, inviting disclosure, opening COP8, offering COP9 or reviewing wider tax affairs.

Type of investigation

We identify whether the case is a compliance check, tax investigation, COP8, COP9, VAT, PAYE, offshore or disclosure matter.

Tax years and limits

The number of years involved affects exposure, discovery, behaviour arguments, interest, penalties and settlement route.

Records requested

Records should be reviewed and explained before submission, especially bank statements, offshore accounts and company records.

Known HMRC information

HMRC may already hold data from banks, property sources, employers, Companies House, platforms or overseas tax authorities.

Behaviour risk

The case should be reviewed for reasonable care, careless, deliberate or deliberate and concealed behaviour risk.

Immediate deadline

Where the deadline is tight, it may be necessary to request time before sending incomplete or unreviewed information.

COP8 and COP9 investigation support

COP8 and COP9 need specialist handling from the first response.

COP8 and COP9 are not routine tax checks. COP8 is commonly associated with complex tax matters, avoidance, offshore structures or significant tax risk. COP9 is used where HMRC suspects fraud and offers the Contractual Disclosure Facility.

COP8 investigation

Review of complex arrangements, offshore issues, avoidance concerns, high-value transactions, trusts, companies and multi-tax exposure.

COP9 and CDF

Support where HMRC suspects deliberate behaviour and the taxpayer must decide how to respond to the Contractual Disclosure Facility.

Disclosure report

Where required, the report needs to explain what happened, quantify tax, interest and penalties, and set out behaviour clearly.

Criminal risk awareness

Serious cases must be handled carefully. False, incomplete or inconsistent statements can create significant risk.

What can trigger an HMRC tax investigation

Investigations often start where HMRC data does not match the tax position reported.

HMRC may not tell you the full trigger at the start. The investigation may be based on tax return entries, third-party information, property records, bank data, offshore reports, VAT differences, PAYE records or earlier correspondence.

Unreported income

Bank deposits, platform income, rental receipts, foreign interest, dividends, employment income or trading income may not match the return.

Property and rental data

HMRC may compare Land Registry, letting agent, mortgage, deposit scheme and tax return information.

Offshore information

Foreign bank accounts, overseas investments, foreign property and CRS data can lead to offshore income questions.

VAT differences

Sales values, VAT repayment claims, input tax, reverse charge treatment or late registration can trigger VAT checks.

Company and director records

Director loans, dividends, private expenses, payroll, benefits and company accounts may create linked tax exposure.

PAYE and employer records

Employment status, P11D, CIS, payroll submissions, expenses and salary sacrifice arrangements can lead to employer review.

Disclosure and settlement strategy

Tax investigations often end through calculation, explanation and negotiated settlement.

Where errors exist, HMRC will usually expect tax, interest, penalties and a clear explanation of how the error arose. The response should be accurate, complete and supported by records.

Tax exposure calculation

We calculate the tax position by year, tax type, source of income, allowable deductions and available reliefs.

Interest and penalties

Interest and penalties are reviewed separately, with attention to behaviour, disclosure quality and cooperation.

Disclosure explanation

The explanation should be consistent with records, tax law, behaviour position and the route used to correct the error.

Settlement with HMRC

We review HMRC’s proposed figures, penalties and closure position before settlement is agreed.

Penalty behaviour review

The behaviour classification can be the most important part of the investigation.

Penalties are not only based on the tax amount. They can depend on whether HMRC views the behaviour as reasonable care, careless, deliberate or deliberate and concealed. The evidence and explanation are critical.

Reasonable care No penalty may be due

Evidence of proper records, advice taken, checks performed and genuine misunderstanding may support a reasonable care position.

Careless Failure to take reasonable care

HMRC may argue carelessness where records were poor, figures were not checked or obvious errors were missed.

Deliberate More serious penalty risk

Deliberate behaviour suggests the taxpayer knew the return or position was wrong. The response must be handled carefully.

Deliberate and concealed Highest civil penalty risk

Concealment may involve false records, hidden accounts, misleading explanations or steps taken to prevent HMRC finding the issue.

HMRC investigation by tax area

A tax investigation can quickly become a multi-tax case.

A personal tax issue can create company tax questions. A VAT issue can create Corporation Tax questions. A payroll issue can create director benefit or company expense questions. We review the whole position before replying.

Personal tax

Self Assessment investigations

Omitted income, unexplained bank deposits, dividends, capital gains, foreign income, property income and repayment claims.

Self Assessment support
Business tax

Company and Corporation Tax investigations

CT600 entries, director loans, dividends, company expenses, related-party transactions, capital allowances and losses.

Corporation Tax support
VAT

VAT investigations

VAT returns, input tax, sales VAT, late registration, reverse charge, partial exemption and repayment checks.

VAT support
Employer tax

PAYE and employer investigations

Payroll records, P11D, benefits, CIS, employment status, salary sacrifice, directors and reimbursed expenses.

Payroll support

How we build the investigation response

The response should be evidence-led, technically correct and proportionate.

HMRC may ask direct questions, but the answer often needs background, calculations, supporting documents and careful wording. We prepare responses that explain the position without creating unnecessary risk.

Fact pattern

We establish what happened, when it happened, who was involved, what records exist and whether advice was taken.

Technical tax position

We review the relevant tax rules, reporting requirements, reliefs, disclosure route and HMRC’s likely argument.

Evidence file

We organise bank records, invoices, accounts, schedules, correspondence and explanations before HMRC submission.

Penalty mitigation

We address behaviour, cooperation, disclosure quality, special circumstances and reasonable care arguments.

Documents needed for HMRC tax investigation support

The first document we need is the HMRC letter.

HMRC correspondence

Opening letter, COP8 or COP9 letter, information requests, penalty notices, assessments, deadlines and previous replies.

Filed tax documents

Self Assessment returns, CT600s, VAT returns, payroll records, company accounts, computations and prior disclosures.

Source records

Bank statements, invoices, contracts, rental statements, foreign tax records, VAT invoices, payroll reports and company ledgers.

Background timeline

What happened, why it happened, who prepared returns, what advice was taken and whether HMRC has already been contacted.

HMRC tax investigation process

A controlled route from HMRC letter to settlement or closure.

1 Review the investigation letter

We identify HMRC’s powers, tax area, deadline, scope, years involved and seriousness of the case.

2 Review records and exposure

We review tax returns, accounts, bank records, VAT, payroll, foreign income and possible underpaid tax.

3 Prepare response or disclosure

We prepare the HMRC response, disclosure report, schedules, calculations or penalty representations.

4 Negotiate settlement and closure

We review HMRC’s figures, penalties, behaviour classification, payment position and closure documents.

HMRC tax investigation fees

Fees depend on the HMRC route, tax years, records, behaviour risk and settlement work.

We quote before work starts. A short investigation letter review is different from a multi-year investigation, offshore disclosure, VAT investigation, PAYE review, COP8, COP9 or penalty negotiation.

Initial investigation review from £300 + VAT

For reviewing the HMRC letter, identifying risk and setting out the immediate next steps.

HMRC investigation response from £1,500 + VAT

For reviewing records, preparing a structured response and dealing with initial HMRC questions.

Complex disclosure or COP case quoted after review

For COP8, COP9, offshore, deliberate behaviour, multi-year, VAT, PAYE or settlement cases.

HMRC Tax Investigation FAQs

Common questions about HMRC investigations, COP8, COP9, disclosures, penalties and settlement.

What is an HMRC tax investigation?

An HMRC tax investigation is a review of a taxpayer’s affairs where HMRC is checking whether the correct tax has been reported and paid. It can involve personal tax, company tax, VAT, PAYE, property income, offshore income or several taxes together.

Is a tax investigation the same as a compliance check?

Not always. A compliance check can be routine or limited in scope. A tax investigation may be wider, more serious, multi-year or linked to suspected behaviour, disclosure issues, COP8 or COP9.

What should I do when I receive an HMRC investigation letter?

You should note the deadline, avoid sending unreviewed records and seek advice before replying. The letter should be reviewed to understand HMRC’s powers, scope and likely risk area.

What is COP8?

COP8 is a Code of Practice used by HMRC’s Fraud Investigation Service for complex tax investigations. It may involve avoidance, offshore issues, high-value transactions, complex structures or significant tax risk.

What is COP9?

COP9 is used where HMRC suspects fraud and offers the Contractual Disclosure Facility. The response is serious and should be reviewed carefully before any acceptance, rejection or disclosure is made.

Can HMRC look back several years?

Yes. How far HMRC can assess can depend on the type of tax, error, behaviour and whether there was failure to notify, carelessness, deliberate behaviour or concealment. Multi-year exposure should be reviewed carefully.

Can HMRC charge penalties in a tax investigation?

Yes. Penalties may depend on behaviour, tax lost, disclosure quality, cooperation and whether the disclosure is prompted or unprompted. Reasonable care arguments should be reviewed where available.

Should I attend an HMRC meeting?

You should not attend without preparation. HMRC meetings can be useful in some cases, but the issues, records, questions and possible exposure should be reviewed before any meeting takes place.

Can a tax investigation be settled without going to tribunal?

Many investigations are settled by agreement with HMRC after tax, interest, penalties and behaviour have been reviewed. Tribunal may be considered where there is a dispute that cannot be resolved by agreement.

Can you deal with HMRC on my behalf?

Once authorised and engaged, we can assist with reviewing HMRC correspondence, preparing responses, disclosure reports, calculations, penalty representations and settlement discussions within the agreed scope.

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