tax investigations

Previous CASES

Tax is always there in most peoples lives. We have been dealing with tax enquiries, investigations and disputes for over 30 years. To say that HMRC is like an old friend wouldn’t be true, however, we have for the most part found their inspectors, officers and lawyers as polite and respectful to deal with, albeit frustrating at times. Cooperation and pro active management of an enquiry is generally the best way to resolve matters. It does not always result in a settlement and we have handled contested appeals to the Tax Tribunal and defendant clients in prosecutions by HMRC and/or the CPS.

Below are some examples of investigations we have handled.

Peter Wilson is a member of the Tax Investigation Practitioners Group.

Tax Appeals

It is not always possible to settle your tax affairs with HMRC without lodging a formal appeal to the First Tier Tax Tribunal. HMRC may issue a formal Determination of tax they say is due, and/or a Decision that National Insurance is owed. You may still be negotiating but the risk of a financial year falling out of assessment (usually a 4 year time limit) may force HMRC's hand.
We are experienced in conducting tax litigation and, at the same time, can continue working towards a resolution on your behalf in accordance with HMRC's Litigation and Settlement Strategy.


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If you are facing a criminal investigation related to tax, you really need professional and properly experienced legal support.  We never recommend attending an interview under caution without a solicitor present and that solicitor should have experience of dealing with HMRC and their approach. We have defended many clients over the years who faced prosecution by HMRC and the Crown Prosecution Service. Having to deal with one or more criminal charges is undeniably a stressful period in life.  Mindful of this, we consider supporting clients in this position as the most important part of our work.  

Code of Practice 9

Entering into a contractual disclosure facility with HMRC, otherwise known as a COP 9 settlement, is no easy decision. For a start, you have to admit fraudulent activity. Then you will need to instruct an appropriately experienced tax investigation accountant to prepare a report on your and/or your business' tax affairs, often going back a number of years. The alternative though could be worse and you could face criminal prosecution but if you have done nothing wrong then COP 9 is not appropriate. We have plenty of experience advising clients objectively and helping them make the right decisions. We can also recommend and work with accountants who specialise in this area.

Other tax issues

Over 30 years we have dealt with a huge variety of tax enquiries and investigations, in many business sectors including construction and engineering, labour supply, restaurants, banking, accountancy, law, electronics, the motor trade, garment businesses, and gold dealing.
We have assisted in with resolving cases concerning all types of taxes, corporation tax, income tax, VAT, Customs Duties, and Inheritance Tax. We have also assisted in resolving a number of National Minimum Wage and Gangmaster Licensing investigations and appeals.

Why Instruct Us

We take the time, and not at our client’s cost, to properly understand the technical and practical detail. This gives us a better insight into the scale of the problem and the solutions available. Its a matter of genuine interest and we have toured many effluent treatment plants, inspected drainage systems, water recycling facilities etc – whatever is needed to deliver the best advice.

What You Get

What you get is dedicated and focused representation, lots of experience of dealing with regulators and a focused, problem solving approach.  Running a business that respects the environment and continually improves sustainability is a constant challenge. The need for objective professional advice is a necessary part of that. Caring for the environment is and will remain critically important and we mean to remain fully involved in this area.

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