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HMRC Investigations

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HMRC is increasingly resorting to coercive measures in order to obtain tax related information, including search and seizure and dawn raids.

Tax investigations are regularly pursued in parallel with related money laundering proceedings under the Proceeds of Crime Act 2002 (POCA).

A tax investigation by Her Majesty’s Revenue and Customs (HMRC) can be unexpected and could have serious implications for you and your business, potentially resulting in severe financial penalties or even criminal proceedings. If you or your business has been contacted by HMRC, you need to act fast and seek professional advice at the earliest possible stage.

New civil and criminal powers given to HMRC have led to record numbers of tax investigations and prosecutions being brought.

At ABV we have noted the real impact of recent legislative changes which has resulted in an increase in HMRC investigations into high net worth individuals, corporates and increased focus upon tax evasion either within the UK or by using off shore mediums.

Professionals such as accountants, solicitors and facilitators of tax avoidance schemes are also liable to investigation and prosecution.

Our Regulatory team has a proven track record of successfully defending both individuals and companies in civil and criminal HMRC investigations in the UK

Including alleged evasion of income tax, corporation tax, VAT and tax avoidance

At ABV we aim to resolve matters before charges are brought wherever possible.

ABV Solicitors work closely with the leading expert accountants and barristers in the country, in order to ensure the strongest possible defence is advanced at court. Our Regulatory team has a proven track record of successfully defending both individuals and companies in civil and criminal HMRC investigations in the UK.


ABV Solicitors have an expert and dedicated team dealing with COP investigations. These investigations are commenced by HMRC when they are suspicious that a serious tax fraud has been committed or significant tax has been lost by deliberate conduct.

It is offered as a one-off opportunity to use a civil solution for a criminal tax evasion. This is known as a Contractual Disclosure Facility (CDF). It is vital to obtain expert advice at the earliest possible stage.

This formal process starts with a letter from HMRC which offers the opportunity to make a full disclosure under a contractual arrangement. There are very strict rules and time limits to follow. HMRC will not reveal what evidence they have. The taxpayer has to either accept or reject/ ignore the offer within the timescales.

Disclosure requires agreement to give complete disclosure of the full extent of the tax evasion. If so, HMRC will agree not to start a formal criminal investigation.  ABV Solicitors will contact HMRC and deal with them on your behalf from the outset taking the stress away from you and ensuring the best possible result is achieved.

Following full and accurate disclosure of the tax irregularities and supporting records, plus formal undertakings to this effect, there will be a civil settlement of tax plus interest plus penalty.

Rejecting or ignoring the offer, or making an inaccurate disclosure are highly likely to lead HMRC commencing a full criminal tax fraud investigation and prosecution.

If you have received a notice then contact our expert team for a consultation.

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