HMRC Enquiries, Discoveries, and other Interventions

HMRC Tax Enquiries & Investigations

HMRC usually has a 12-month window from the date your tax return is submitted to open a tax enquiry. This window may be extended if you file late or amend your return.

Each year, HMRC launches thousands of tax compliance checks—often referred to as HMRC investigations—to verify that tax returns are accurate and complete. These compliance checks can target specific items such as reported income or capital gains. Some HMRC tax enquiries are also selected at random to help deter tax evasion and maintain fairness in the tax system.

Being the subject of a HMRC compliance check does not necessarily mean there is firm evidence of wrongdoing. In fact, many enquiries are closed without any amendments. However, dealing with an HMRC enquiry can be time-consuming, stressful, and costly—especially without the right support. Even if the enquiry results in no changes, HMRC does not reimburse your professional fees or time.

Discovery Assessments by HMRC

Outside the standard enquiry window, HMRC can raise what are known as discovery assessments if they uncover new information or believe your return was carelessly or deliberately inaccurate. These can go back:

• 4 years for careless errors
  
  
• 6 years where income is under-reported
  
  
• Up to 20 years in cases of deliberate tax evasion

These types of HMRC tax investigations require specialist advice and a proactive approach.

Offshore Non-Compliance and HMRC Nudge Letters

HMRC now has stronger powers to investigate offshore income and assets, including extended time limits, higher penalties, and even strict liability offences.

Through international agreements and data sharing arrangements like the Common Reporting Standard, HMRC receives data from hundreds of jurisdictions. If they suspect offshore non-compliance, they may issue a HMRC nudge letter, officially called an Offshore Income and Gains Letter.

If you receive such a letter, it’s critical to seek professional guidance immediately. We’ve supported many individuals through disclosures via the Worldwide Disclosure Facility (WDF) and can help clarify your obligations.

HMRC Civil Investigations – COP8 and COP9

For serious tax issues or suspected fraud, HMRC initiates Code of Practice 8 (COP8) or Code of Practice 9 (COP9) investigations. These are carried out by HMRC’s Fraud Investigation Service (FIS) and often involve substantial underpaid tax.

Such serious HMRC investigations require careful handling and experienced representation. We ensure every aspect is managed professionally, protecting your interests throughout the process.

Our HMRC Investigation Services

Our team of tax advisors have extensive experience dealing with HMRC compliance checks, tax enquiries, and disclosure processes. Whether it's a routine enquiry or a complex HMRC investigation, we will:

• Handle all communications with HMRC on your behalf
  
  
• Ensure your legal rights are protected
  
  
• Negotiate fair outcomes, including reduced penalties and interest where applicable
  
  
• Engage with HMRC in a constructive and cooperative way—leading to better results for you

We can help with:

• Responding to HMRC tax enquiries and discovery assessments for individuals, businesses, and trusts
  
  
• Making disclosures under the Worldwide Disclosure Facility for offshore income and gains
  
  
• Advising accountants, solicitors, and agents on complex HMRC issues
  
  
• Preparing voluntary disclosure reports under available HMRC amnesties

If you've received a compliance check letter, nudge letter, or have concerns about an ongoing tax investigation, don’t wait.

If you require tax advice in any other areas of UK Private Client Tax, please click here to find out more.

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