HMRC Investigations Solicitors

HMRC investigates suspected serious tax fraud through its specialist Fraud Investigation Service, most commonly under Code of Practice 9 (COP9) — where HMRC suspects deliberate fraud but offers a Contractual Disclosure Facility as an alternative to prosecution — or Code of Practice 8 (COP8), used for serious suspected avoidance or irregularities that fall short of fraud.

Which code of practice applies changes what the investigation is really about and what your options are, which is why understanding the letter you've actually received matters before you respond to it.

HMRC's powers extend to dawn raids, interviews under caution, and account freezing or seizure of business records. Left unanswered, a criminal investigation can lead to prosecution, unlimited fines, and up to 7 years' imprisonment depending on the offence.

Acting early — including making a full and accurate disclosure where that's the right course — is often what prevents a case escalating from a civil tax dispute into a criminal prosecution.

We advise on your rights and options from the first contact with HMRC's criminal investigators, including at interview, in response to any search or production order, and on whether a Contractual Disclosure Facility is the right route for your circumstances.

• Advice on HMRC's criminal investigation powers
• Representation at interview under caution
• Advice in response to search warrants or production orders
• Representation if the case proceeds to prosecution