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This is the most serious stage of HMRC scrutiny — and the stage where experienced representation matters most.
A formal tax investigation goes beyond a routine compliance check. It usually means HMRC suspects a more significant or deliberate error, and the case is being handled by specialist investigators — potentially under Civil Investigation of Fraud procedures, or in rare cases referred for criminal investigation.
Formal investigations carry the risk of much larger penalties — up to 100% of the tax owed (or 200% for offshore matters) where behaviour is judged deliberate — alongside published “naming and shaming” for the most serious cases, and, in extreme circumstances, criminal prosecution. The investigation will also typically look back further than a standard check: up to 20 years in cases of suspected deliberate behaviour.
We manage all communication with HMRC’s investigation team, so you are never responding under pressure or off the cuff.
We conduct an independent review of your affairs first, so we know your real exposure before HMRC tells us theirs.
We prepare a full, accurate disclosure where one is needed — voluntary and well-organised disclosure is the single biggest lever for reducing penalties.
We negotiate behaviour classification (careless vs. deliberate) and penalty levels directly with HMRC.
Where a case carries any risk of criminal referral, we work alongside specialist tax counsel to protect your position.
We keep you informed at every stage and make sure decisions are taken with your best interests in mind.
Concerned a compliance check is escalating into something more serious? Speak to an Expert now, before your next HMRC contact.
The single biggest driver of penalty levels in an investigation is how HMRC classifies your behaviour — careless, deliberate, or deliberate and concealed. That classification is shaped heavily by how organised, complete, and cooperative your response is from the very first meeting. Getting this right from day one, rather than trying to recover from an early misstep, is where specialist representation earns its value.
If HMRC has opened a formal investigation into your affairs, contact us today. All initial conversations are confidential and without obligation.
For most investigations, a specialist tax accountant is sufficient. We bring in tax counsel or solicitors only where there’s a realistic risk of criminal proceedings.
Yes — the large majority are resolved by negotiated settlement (a “contract settlement”) without ever reaching tribunal.
This matters significantly for penalty classification. We help establish and evidence this clearly to HMRC from the outset.
Book an appointment with our specialists today.