Facing an HMRC tax investigation? Specialist accountants on your side.

Calm, expert representation when HMRC opens an enquiry into your tax affairs.

Opening a letter from HMRC can be a real worry. The good news is that an enquiry is survivable, and you do not have to face it alone. From the first letter to the final settlement, our qualified tax investigation accountants handle your case for you. That covers a single questioned figure on your Self Assessment (the tax return you file each year), a full enquiry into your company, or a Code of Practice 8 or 9 notice, which are HMRC's most serious investigations. We deal with the correspondence, challenge demands that are not reasonable, and work to reduce the tax, interest and penalties. You get fixed pricing, one named contact, and a reply within 72 hours, so you are never left guessing while the clock runs.

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What is an HMRC tax investigation?

An HMRC tax investigation is any formal check into whether you have paid the right amount of tax. Most start as a compliance check, which is HMRC’s own name for an enquiry into a return or a specific figure. The great majority are civil. They are settled by paying the correct tax, interest and a penalty, with no question of court. Our tax investigation specialists handle every type, civil or criminal.

A small number are criminal. These are run by HMRC’s Fraud Investigation Service (FIS) and are reserved for the most serious, deliberate cases. It helps to understand three things people often muddle, because they carry very different risk. Tax avoidance means using the rules to reduce tax, which is legal, though HMRC challenges aggressive schemes. Tax evasion and tax fraud mean hiding income or claiming relief you are not due, which is not. We work out which category HMRC is really treating your case as, and make sure you have professional representation from the first letter.

What triggers an HMRC tax investigation

Most investigations are not bad luck. HMRC’s Connect system cross-checks your returns against bank data, the Land Registry, the DVLA and information from online platforms such as eBay, Vinted and Airbnb. An enquiry is usually opened when something does not add up. Common red flags include:

  • Figures that are inconsistent year on year, or out of step with others in your sector
  • Persistent late filing or late payment
  • Undeclared income, including side-hustle or rental income
  • Large or unexplained swings in profit, expenses or margins
  • Cash-heavy trades such as construction, hospitality and taxis
  • Offshore income or assets
  • A tip-off from a third party

A small number of checks are genuinely random, so even an accurate return can be selected. If you have been contacted and the reason is not obvious, we will help you work out exactly what HMRC is looking at.

What to expect during an HMRC investigation

Every case is different, but most follow the same path. Knowing the stages makes the process far less stressful.

  1. Opening notice. HMRC writes to you, often with a Schedule 36 information notice setting out the records it wants and the deadline.
  2. Information and review. HMRC examines your records and may ask questions or request a meeting. You do not have to respond, or attend, alone.
  3. Assessment. HMRC sets out what it believes is owed, with any interest and penalties, and we negotiate that position on your behalf.
  4. Resolution. The enquiry ends with a closure notice and, where appropriate, a settlement. If agreement cannot be reached, you have the right to a review and an appeal.

Which taxes an investigation can cover

An enquiry can touch any tax you pay, and a single case often spans more than one. We handle the full range:

  • Income Tax and Self Assessment, for sole traders, the self-employed and company directors
  • Corporation Tax for limited companies
  • VAT, including control visits and registration checks
  • PAYE, National Insurance (NIC), benefits in kind and employment status
  • Capital Gains Tax (CGT) on property, shares and business sales
  • Inheritance Tax (IHT) on estates and lifetime gifts
  • The Construction Industry Scheme (CIS) for contractors and subcontractors
  • IR35 and off-payroll working
  • Cryptoassets, where reporting is tightening under the Cryptoasset Reporting Framework (CARF)
  • Offshore income and assets, where the penalties and time limits are harsher

If HMRC opens on one tax and tries to widen the enquiry to another, we keep the scope contained and deal with every part as a single case.

See also: Corporation TaxVATCapital Gains TaxSelf Assessment

How HMRC decides who to investigate

Very little is random. HMRC’s Connect system pulls together data from banks, the Land Registry, online platforms and overseas tax authorities, then flags returns that do not match the picture. If your figures sit outside it, an enquiry can follow.

The reach keeps growing. Digital platforms such as eBay, Vinted, Airbnb and Etsy now report seller income directly to HMRC. Making Tax Digital (MTD) will bring more frequent reporting for the self-employed and landlords. A Financial Institution Notice (FIN) lets HMRC demand information from your bank without a tribunal’s permission. Through the Common Reporting Standard (CRS) and FATCA, more than 100 countries exchange account data, so offshore income is far easier to spot than it once was.

Many checks now begin with a nudge letter, a prompt to review a particular source of income before any formal enquiry is opened. These are easy to answer badly. We help you reply in a way that closes the matter rather than opening a wider one. HMRC can also test your lifestyle and personal spending where declared income looks too low to support it, and businesses can face the Corporate Criminal Offence (CCO) rules where they fail to prevent the facilitation of tax evasion.

Our expertise covers

What our tax investigation service covers

  • 01

    Compliance checks and aspect enquiries

    Most HMRC contact starts as a compliance check: a letter questioning one or more specific figures, such as expenses, a property sale or undeclared income. This is also called an aspect enquiry, because it looks at one aspect of your return rather than the whole thing. We work out what HMRC is actually entitled to ask for, gather only the documents needed, and reply inside the deadline, usually 30 days, asking for more time where that is reasonable. Handling an aspect enquiry properly and early often stops it growing into a full enquiry.

  • 02

    Full enquiries into Self Assessment and company tax returns

    In a full enquiry, HMRC looks at your whole return rather than one figure. We act as your agent from start to finish, deal with or decline meetings for you, and keep the enquiry on the points in dispute instead of a wider trawl. We also check the timing. HMRC normally has to open an enquiry within 12 months of the date you filed the return. If it has missed that window, we say so.

  • 03

    Discovery assessments and time limits

    Sometimes HMRC raises a tax bill for an earlier year after the normal window has closed. This is called a discovery assessment. How far back it can go depends on what caused the error: 4 years for an innocent mistake, 6 years for carelessness, and up to 20 years where the underpaid tax was deliberate. We check the assessment is valid, test whether HMRC has really made a new discovery, and where the time limit has passed we argue that it cannot stand.

  • 04

    Penalties, behaviour and suspension

    How much you pay in penalties depends on behaviour, not just the tax. For an inaccuracy, a careless mistake is 0 to 30% of the extra tax, deliberate is 20 to 70%, and deliberate and concealed is 30 to 100%. You reach the bottom of each band by coming forward before HMRC asks and cooperating fully. We argue for the lowest behaviour category and push for the biggest reduction for telling, helping and giving access. Where a penalty is careless, we ask HMRC to suspend it against future conditions, which can mean nothing is actually paid.

  • 05

    COP8 and COP9 serious investigations

    These are HMRC's most serious investigations, and you should never reply to one on your own. Code of Practice 8 (COP8) is used when HMRC suspects a large tax loss, but not fraud. Code of Practice 9 (COP9) is used when it suspects deliberate fraud, and it comes with the Contractual Disclosure Facility (CDF): the chance to make a full disclosure instead of facing criminal prosecution. The penalties can reach 100%, and you have just 60 days to send the outline disclosure. We work alongside specialist tax counsel where needed, prepare the outline and full disclosure, and stop the enquiry widening by accident.

  • 06

    Voluntary disclosures and settlement

    If you know something is wrong before HMRC asks, telling them first is almost always the better move. It earns the largest penalty reductions and makes a deliberate-behaviour finding far less likely. We make the disclosure through the right route for your case, the Digital Disclosure Service, the Let Property Campaign or the Worldwide Disclosure Facility, work out the tax, interest and any penalty, and agree a settlement or a time-to-pay plan if you cannot pay it all at once. If HMRC will not settle fairly, we handle the review and a First-tier Tribunal appeal.

  • 07

    VAT investigations and control visits

    HMRC can inspect your VAT records and visit your premises to check returns, registration and the rates you have applied. We handle the visit, answer the queries and challenge any assessment we believe is wrong.

  • 08

    PAYE and employer compliance reviews

    If you employ people, HMRC can review PAYE, benefits in kind, expenses and your employment-status or IR35 decisions. We keep the review proportionate and make sure any settlement is fair.

Who we work with

Who we help.

  • Contractors and the self-employed

    IR35 status challenges, CIS disputes and Self Assessment enquiries, defended with your real working practices and contracts.

  • Landlords and property investors

    Undeclared rental income, the Let Property Campaign and Capital Gains Tax on disposals, brought up to date and disclosed correctly.

  • Construction and CIS

    Subcontractor status, verification and cash-in-hand suspicions, an area HMRC treats as high risk.

  • Hospitality and cash trades

    Takings, margins and till records in cafes, restaurants, takeaways and taxis, where HMRC scrutiny is heaviest.

  • Owner-managed companies

    Director loan accounts, dividends, expenses and PAYE reviews for small and growing limited companies.

  • High-net-worth individuals

    Complex affairs, offshore income and assets, and disclosures through the Worldwide Disclosure Facility, handled discreetly.

Why use a tax investigation specialist, not just your accountant

A general accountant prepares your returns. Defending an investigation is a different job. HMRC’s enquiry teams do this every day, so you need someone on your side who does too. Our tax investigation accountants focus on exactly this work.

We focus on the investigation itself: understanding exactly what HMRC can and cannot ask for, controlling what information is shared and when, managing any disclosure correctly, and arguing the behaviour and penalty position rather than simply accepting it. That is often the difference between a quick, low-cost settlement and a long, expensive one. We work alongside your existing accountant or bookkeeper, so nothing changes day to day.

Fee protection and our Tax Investigation Service

An enquiry can cost money to defend even when no extra tax turns out to be due, because the work takes time whatever the outcome. Fee protection, sometimes sold as a Tax Investigation Service (TIS), is a small subscription that covers our professional fees if HMRC opens a check. It does not change any tax you owe, but it takes the cost of representation off the table.

Timing matters too. A disclosure you make before HMRC contacts you is unprompted, and it attracts the lowest penalties. Once HMRC has written to you, a disclosure is prompted, and the reductions are smaller. We will tell you honestly which position you are in and the cheapest legitimate way through, and our tax investigation accountants manage the whole disclosure for you.

Where we work

We represent clients facing HMRC enquiries across the United Kingdom and work remotely, so your location is no barrier. We act for individuals and businesses in London, Reading, Berkshire, Surrey, Yorkshire, Leeds, Bradford, Sheffield, Stoke-on-Trent, Milton Keynes, Hitchin, Harrow, Bracknell, Crowthorne, Swansea, Glasgow and the surrounding areas.

Whether you are looking for a tax investigation specialist in London, an HMRC enquiry accountant in Leeds, or simply tax investigation help near you, the service is the same: one named accountant, fixed pricing, and everything handled by phone, email and secure upload.

Why it pays off

Why work with our tax investigation specialists

  • A named, qualified accountant on your case

    You deal with one qualified person who knows your file, not a call centre. They speak to HMRC so you do not have to, and every letter and figure goes through someone who has handled enquiries before.

  • Fixed pricing, no surprise bills

    Our plans are priced at a clear £99, £199 or £499, agreed up front. You will not get a frightening hourly invoice on top of an already stressful investigation, and a 30-day money-back guarantee backs the work.

  • Replies within 72 hours

    HMRC enquiries run on deadlines, and silence costs money. We commit to responding within 72 hours so documents go back on time, extension requests are made early and penalties for delay are avoided.

  • We argue down the penalty, not just pay it

    Many taxpayers accept HMRC's first penalty position. We challenge the behaviour category, push for the maximum reduction for disclosure and cooperation, and seek suspension of careless penalties, which can mean paying far less or nothing in penalties.

  • Works with your existing bookkeeping

    We pull the records HMRC needs straight from Xero, QuickBooks, FreeAgent or Sage, so reconstructing the position is quick and accurate. On a rolling monthly arrangement you can stay supported after the enquiry closes.

How far back can HMRC go?

How many years HMRC can reopen depends on the behaviour behind the error. The more careless or deliberate the mistake, the further back it can reach.

For Self Assessment, HMRC normally has to open an enquiry within 12 months of the date you filed. After that, it needs a discovery assessment, which is where these longer time limits apply.

Behaviour behind the errorHow far HMRC can go back
Innocent error4 years
Careless mistake6 years
Deliberate behaviour, or offshore mattersUp to 20 years
How we deliver

Four steps from first call to filed.

  • 01

    Discovery

    Understanding your business needs.

  • 02

    Solution Design

    Crafting your custom accounting strategy.

  • 03

    Onboarding

    Quick and easy integration.

  • 04

    Regular Rhythm

    Consistent monitoring and reporting.

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Common questions

Frequently asked questions.

Most enquiries start with a computer flagging a mismatch. HMRC cross-checks your return against reports from banks, online platforms and Companies House, and an enquiry can follow a mismatch, risk profiling of your industry, a tip-off, random selection, or an unusual jump in your figures from one year to the next. HMRC does not have to tell you why. The first letter looks intimidating, but it is usually a standard opening notice, and what you send back in the first 30 days sets the tone for the whole enquiry.

COP8 covers cases where HMRC suspects significant tax loss but not deliberate fraud. COP9 is the Contractual Disclosure Facility, HMRC suspects deliberate fraud and is offering you immunity from criminal prosecution in exchange for a full, accurate disclosure within 60 days. COP9 is far more serious and you must never respond to one without specialist representation. We've handled both end-to-end.

IR35 is the rule that decides whether a contractor is genuinely self-employed or really a hidden employee for tax. We defend a status challenge on the three things that decide it: whether you have to do the work yourself, how much control the client has over how you work, and whether there is an ongoing obligation to offer and accept work. We back this with your real working practices, your contracts and the end client's evidence. We also review any CEST result (HMRC's online Check Employment Status for Tax tool), though it is rarely decisive on its own. The earlier we get involved, ideally before HMRC issues a decision, the stronger your position.

Yes. Penalties scale by behaviour: 0-30% for careless errors, 20-70% for deliberate, and 30-100% for deliberate and concealed. Within each band, full unprompted disclosure and cooperation can cut the penalty to the minimum. Reasonable excuse arguments can remove penalties entirely in some cases. Our job is to position your facts in the band and percentage that costs you least.

For many clients, yes. Fee protection is a small subscription that covers our professional fees if HMRC opens an enquiry, so you are not paying to defend yourself on top of any tax that turns out to be due. Without it, defending even a straightforward enquiry can run into thousands of pounds in fees, because the work takes time whatever the outcome. The cover does not change the tax you owe, but it takes the cost of fighting your corner off the table. Most clients add it once they understand how it works.

It depends on your behaviour. HMRC can normally go back 4 years, rising to 6 years where a mistake was careless, and up to 20 years where income was deliberately hidden or involves offshore matters. For Self Assessment, HMRC usually has 12 months from the date you filed to open an enquiry, but a discovery assessment can reach back further.

They are largely the same thing. "Compliance check" is HMRC's own term for an enquiry into your tax affairs. "Audit" is the American word people often use, but in the UK there is no separate process called a tax audit. Whatever it is called, the way we defend it is the same.

A simple aspect enquiry into one figure can be resolved in a few months. A full enquiry, or a serious fraud investigation under COP8 or COP9, can run for a year or more. The sooner you get specialist representation and the better organised your records, the faster it usually ends.

The vast majority of investigations are civil and are settled by paying the tax, interest and a penalty. Criminal prosecution is reserved for the most serious deliberate fraud. Where there is a risk, HMRC may offer the Contractual Disclosure Facility under COP9, which protects you from prosecution in exchange for a full disclosure. We will tell you clearly where you stand.

You do not have to accept HMRC's conclusion. You can request an independent internal review, use Alternative Dispute Resolution to reach a settlement, or appeal to the First-tier Tax Tribunal. We will advise which route gives you the best outcome.

No. Once you appoint us as your agent, HMRC deals with us, not you. We handle the letters, the calls and any meeting. You do not have to attend an interview alone, and in a serious case you should not. Having a representative speak for you keeps the case calm and stops a nervous, off-the-cuff answer turning into a bigger problem.

Tax avoidance means arranging your affairs within the law to pay less tax. It is legal, though HMRC challenges aggressive schemes. Tax evasion means hiding income, inflating expenses or failing to declare something you should, which is illegal and can be treated as fraud. The line matters, because evasion carries far higher penalties and, in the worst cases, criminal prosecution. We will tell you honestly which side of it your case sits on.

Not always. HMRC can demand records that are reasonably required to check your tax, usually through a Schedule 36 information notice with a deadline. But it is not entitled to everything. Some requests can be narrowed, challenged or refused. We review every notice, hand over what the law requires, push back on what it does not, and negotiate more time where the deadline is too tight.

Zmartly Ltd20-22 Wenlock Road, London N1 7GU020 8175 5145info@zmartly.co.uk
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