Investigations

We assist clients facing HMRC investigations, often alongside other regulators, including civil tax fraud and corporate criminal matters. We also conduct internal investigations and manage sensitive disclosures with discretion and clarity.

Tax investigations often arise at moments of heightened sensitivity. Internal concerns about potential errors, suspected fraud or whistleblower allegations can create significant uncertainty. External enquiries from HMRC can feel intrusive, fast‑moving and reputationally concerning. We understand the pressure these situations create and provide clear, discreet support where matters require careful handling from the outset.

We advise on the full range of internal and external tax investigations. For corporates, this includes privileged internal investigations where tax issues are suspected, establishing potential liabilities and managing any necessary disclosures to HMRC. We also assist where concerns arise from wider regulatory, employment or governance reviews, including cases involving suspected employee fraud or the possible facilitation of tax evasion.

We support financial institutions facing HMRC enquiries relating to potential MTIC exposure, helping them review transactions and strengthen controls. Where auditors raise questions about tax positions or provisions, we assess the underlying position, gather evidence and challenge audit views where appropriate.

For individuals, HMRC investigations can be highly personal, with significant financial and reputational implications. We act for high‑net‑worth individuals, executives, trustees and family offices across the full range of personal tax enquiries, including residence and domicile issues, offshore structures, investment income, gains and employment‑related matters. We also advise where HMRC receives information from financial institutions, intermediaries or whistleblowers. Our support is discreet, legally privileged and focused on resolving matters efficiently.

Our work covers all aspects of the investigative process, including drafting responses to HMRC on factual and technical issues, handling information requests, managing data collection and e‑discovery exercises. We help clients stay on the front foot, reducing the risk of escalation, unnecessary scrutiny and potential penalty exposure.

We are acutely aware of the potential reputational consequences of enforcement action, regulatory reporting or litigation. Following resolution, we assist clients in strengthening systems and procedures to reduce future exposure and demonstrate robust compliance. Whatever the scope of the enquiry, we provide pragmatic, senior‑led support focused on protecting financial and reputational interests.


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Nick Skerrett

For a sharper perspective on your position

Nick Skerrett
Partner

T +44 (0)20 4591 0771
E nick@resolutiontax.co.uk

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