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HMRC Investigatons

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.

 

HMRC CODE OF PRACTICE 9 (COP9) – CONTRACTUAL DISCLOSURE FACILITY (CDF)

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.

Notable Cases

Operation Cocoa – Guildford Crown Court

Large Conspiracy to Evade Duty on VAT in respect of high value jewellery, gold and diamonds allegedly being exported out of the U.K. Case required defence enquiries to be made in the Dubai gold souks.

Operation Toolshed – Kingston Crown Court

This case concerns a multi handed Evasion of Duty, which involved the importation from Kuwait of a very large quantity of cigarettes, which resulted in a huge loss to the Revenue.

Operation Curtain – Investigation Stage

This investigation involves substantial surveillance by HMRC on the illicit activities of a number of individuals suspected of being involved in the fraudulent evasion of circa £2 million cigarettes. A vast amount of cash was seized during the investigation and a number of arrests have been made for the evasion of duty and for money laundering.

Operation Bombard – Investigation Stage

HMRC in conjunction with the UK Border Force are leading this extensive investigation relating to the seizure of millions of pounds worth of cigarettes which were imported in several consignments into Heathrow Airport. The case involves substantial surveillance including convert and intrusive surveillance.

Operation Varlet – Kingston Crown Court

Multi-handed Missing Trader/VAT Fraud worth millions of pounds of lost revenue generated from the supply of significant amounts of mobile phones in Europe.

R v Z – Southwark Crown Court

The case is split into two sections: a Multi-million pound VAT carousel fraud and duty evasion on cigarettes imported into the UK. Defendants were alleged to have falsely created companies to orchestrate transactions where a substantial amount of VAT was owed to the Revenue. Cigarettes were bought into the UK through importations of tissues and noodles.

Operation Eiger – Southwark Crown Court

This case concerned a huge Conspiracy to Evade Duty and VAT of circa £40 million relating to the smuggling of tobacco from China and Russia. The case involved three separate trials due to the number of defendants involved. The case was one of the largest prosecutions of its time.

R v Z – Birmingham Crown Court

A £150 million corporation tax fraud where allegedly work was declared, that had not been undertaken, for an innovative project in science and technology in order to claim Research and Development Tax Relief. There is a complex arrangement of companies in the haven islands and overseas which requires detailed analysis of legal documents.

Operation Trickshot – Guildford Crown Court

Case concerned multi-million pound charges of Cheating the Public Revenue and Money Laundering. The nature of the fraud was to take advantage of the VAT system which allows the Zero Rating of invoices and permits for any VAT spent on expenses incurred to be claimed by producing falsifying documentation. Defendant was also subject to complex Restraint Order and confiscation proceedings concerning multiple third parties.

Operation Inertia – Kingston Crown Court

A high-profile case described as one of the largest Missing Trader / VAT Fraud investigation in the UK. The fraudulent companies involved ran a turnover, which was well in excess of £170 million. Companies both in the UK and in Europe were set up to falsely claim to sell mobile phones and other electronics in order to eventually syphon the VAT owed.

Operation Fusion

 – Southwark Crown Court

This multi defendant case investigated by HMRC involved a very large and serious Diversion Fraud relating to the export of vast sums of alcohol worth millions of pounds and fictitious bonded warehouses. The case related to the infamous London City Bond cases, which were successfully appealed before the Court of Appeal, due to evidence relating to paid informants.

Operation Goodies/ R v Bajwa & Others [2011] EWCA CRIM 1093 REPORTED CASE 
- Manchester Crown Court 2008


Multi handed Conspiracy to Evade Duty on millions of smuggled cigarettes from China. The Proceeds of Crime Act Confiscation proceedings, which followed were one of the largest in the U.K and were delayed as a result of the case of R v May on Apportionment and Criminal Lifestyle.

Operation Clumber
 – Harrow Crown Court

Multi-handed conspiracy to Evade Duty on the importation of vast consignments of Cigarettes and Tobacco resulting in a loss to the Revenue of many millions of pounds. The surveillance operation involved many officers over a lengthy period of time both in the U.K and in a number of countries in Europe.

Operation Lighthouse – Maidstone Crown Court

Multi-handed duty evasion case involved an operation, which lasted in excess of 15 months. The defendants are alleged to have brought alcohol into the country without the appropriate duty being paid. The estimated loss to the Revenue being in the region of £2 million.

Operation Spartan – Croydon Crown Court

This was a large scale VAT fraud within the construction/ labour industry which dealt with bogus CIS (Construction industry Scheme) claims. The loss to the Revenue amounted to millions of pounds. Our client was acquitted of all charges. Numerous enquires were made on the defendants behalf in India which assisted in the defendants acquittal.

Operation Savate – Birmingham Crown Court

One of the largest frauds to be carried out using the Construction Industry Scheme (CIS) with £8 million loss to the Revenue. Allegations included Cheating the Revenue of VAT, Income tax, Corporation Tax and National Insurance Contributions and Money Laundering. Illegal activity involved more than 100 businesses across the country whose identity was either hijacked or were part of the fraud.

Operation Duma – Birmingham Crown Court

Large Multi Handed VAT Carousel Fraud, investigated by Revenue Customs Prosecution Office. The loss was in several millions of pounds. The prosecution disclosure in this matter was very substantial.

Key Individuals

Deepak Vij

Deepak Vij

Director

Robert Borwick

Robert Borwick

Director

Akhtar Ahmad Solicitor London Specialist fraud crime

Akhtar Ahmad

Director

Amirah Ajaz Solicitor Fraud Specialist London

Amirah Ajaz

Solicitor

Fergus Harrington London Specialist fraud city of london ABV

Fergus Harrington

Solicitor

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