You should consider a tax investigation specialist when an HMRC enquiry involves disputed figures, several taxes or accounting periods, possible penalties, or concerns about deliberate behaviour. A straightforward request may be manageable with your usual accountant. The right level of support depends on the issues raised, the evidence available and the deadlines you face.
The first step is to understand what HMRC is asking. Its compliance check guidance explains that checks establish whether the correct tax has been paid and the right reliefs claimed. A request for information does not, by itself, establish that tax is owed or that fraud has occurred.
A specialist helps you examine the tax position and respond with a clear, evidence-based explanation. Agree the scope of their work at the outset. Depending on the case, this can include:
An adviser cannot promise that HMRC will close the case without adjustments, or guarantee a particular saving. Their role is to establish the facts, explain your position and help you make informed decisions.
Start by asking your accountant whether they have experience of the issue HMRC has raised. If the question concerns a specific expense and the records clearly support the return, your accountant may be well placed to reply.
Specialist input becomes more useful when the enquiry needs technical knowledge or investigation experience beyond their usual work. You can ask a specialist to work alongside your accountant, with responsibilities agreed between everyone involved.
Consider specialist input if questions span VAT, PAYE, Corporation Tax or personal tax, or involve overseas income and assets. Ask how the adviser will reconcile records across the different taxes and identify whether an answer in one area affects another.
Missing invoices, unexplained transfers or differences between bank receipts and declared income need careful examination. An adviser can help reconstruct the position and distinguish evidence from assumptions. Tell them where records are incomplete; do not create documents that suggest missing evidence existed.
Ask for advice if you do not understand the basis of an adjustment or disagree with the behaviour HMRC attributes to you. HMRC explains that penalties can depend on why tax was underpaid, when it was told and the help provided during the check. A reduction is not automatic. See HMRC tax compliance checks.
Some decisions and penalties can be challenged. The available procedure depends on the decision, so have the notice and its deadline checked promptly. GOV.UK explains the routes for disagreeing with a tax decision or penalty.
A Code of Practice 9 case needs particular care. HMRC strongly advises independent professional advice before responding to a Contractual Disclosure Facility offer and notes that a COP9 specialist may work alongside your regular adviser. The offer has a 60-day response period from receipt. This is a specific COP9 rule, not a deadline for every HMRC enquiry.
Do not assume that accepting the offer is the right response in every case. The facility concerns deliberate behaviour causing a tax loss, and its protection depends on meeting the terms. Read HMRC Code of Practice 9 and obtain advice suited to the allegations. Where criminal investigation is involved, seek a solicitor with relevant expertise.
Send the complete HMRC letter, including attachments, and highlight the response date. Gather the relevant returns, accounts, earlier correspondence and the records connected with the questions. Add a short timeline explaining what happened and flag anything you think may be incorrect.
Preserve original records and correspondence. If you hold fee protection cover, check its terms and any notification requirements before commissioning work. For the initial response steps, see what to do when you receive an HMRC investigation letter.
Look for experience relevant to your case rather than broad claims about success. A useful first discussion should explain the immediate priorities and the information needed to assess your position.
Agree the engagement and the authority needed for HMRC to correspond with the adviser. Do not assume that appointing someone removes your responsibility to provide accurate information. Keep copies of the submissions made on your behalf.
At Apex Accountants, we support individuals and businesses with HMRC correspondence, record preparation and explaining their tax position. Our HMRC tax investigation service covers enquiries across different areas of tax.
Rana Zubair worked briefly within HMRC earlier in his career and has since gained many years of experience advising individuals and businesses through enquiries and investigations. His experience includes VAT, PAYE, Corporation Tax, personal tax, property, Capital Gains Tax, overseas income and overseas assets.
If you have received a letter, book a consultation to discuss the questions raised, the response deadline and the support your case may need.
No. Assess the complexity with your usual accountant. A focused request with clear supporting records may need less support than an enquiry involving disputed treatment, several taxes or suspected deliberate behaviour.
No. The outcome depends on the facts and applicable rules. An adviser can examine the basis of a penalty and present relevant evidence, but should not promise a reduction.
If a response date is approaching, contact an adviser with the letter and the records you already hold. Explain what is missing so they can assess the immediate priorities. Do not assume extra time has been granted.
General guidance checked against the linked official sources on 20 October 2026. The appropriate response depends on the HMRC correspondence and the facts of your case.
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