Pure Tax Investigations

20/07/2026

📢 We know that are busy most of the time, with their portfolios of clients and those demands.

🔔 However, we are noting increased activity from 's Fraud Investigation Service (see here: https://pure-tax.com/fraud-investigation-service/ ). That's where the most serious investigations are carried out.

📢 In an article we penned for Bloomberg Tax at the end of 2025, we highlighted that HMRC had opened some 450 Code of Practice 9 (COP9) tax fraud investigations and Code of Practice 8 (COP8) serious civil investigations. These should not to be under-estimated, in terms of the experience and knowledge required to manage them well, ensuring clarity and certainty for clients, and getting the best results for our entrepreneurial and business clients. We help them find that light at the end of the tunnel.

📣 So, if you're sitting on an old or new COP9 (https://pure-tax.com/tax-investigation-hmrc/cop9-code-of-practice-9/ ) or COP8 (https://pure-tax.com/tax-investigation-hmrc/code-of-practice-8/ ) investigation, and feeling a little lost or prefer that someone else manages it to better preserve your long-term client relationship, please get in touch with us ASAP.

📞 Also, we understand people often need to speak to us out of hours, e.g. early in the day, evenings and on weekends. So we ensure we're flexible and available, to listen and advise, on a no obligation and confidential basis.

Pure Tax Investigations -pure-tax.com
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0203 7575 669

16/07/2026

Great article explaining why equalising CGT with Income Tax would be ‘act of economic self-harm’ by Andy Oury for Croner-i. See here: https://www.accountancydaily.co/equalising-capital-gains-income-tax-would-be-act-economic-self-harm

"Incoming prime minister Andy Burnham is reportedly considering bringing capital gains tax (CGT) into line with income tax - taking the rate from 24% to as much as 45%. Even Sir Tony Blair’s own institute has warned him off, and rightly so.

"Assets are not income. Income arrives whether you like it or not; a gain only exists if you choose to sell. That single difference is why equalisation fails everywhere it is tried, and why the behavioural response is so brutal.

"Try this test on anyone you know. Imagine you own something worth £200,000 - a flat, a stake in a company, whatever you like - and the tax on selling is 45%. Would you sell? I have asked this question many times and I have never once heard yes. People hold. They borrow against the asset, rent it out, pass it on - and the Exchequer collects nothing at all.

"This is not theory. When the main rate rose to just 24%, the response was strong enough that the Office for Budget Responsibility (OBR) cut its medium-term CGT forecast by more than £5bn, its models now assuming business-sale disposals fall 15% one year and 30% the next.

"Somewhere above 20% is where the ordinary person’s sense of fairness snaps and the selling stops. At 45% - reportedly the highest rate in Europe - it would not slow; it would halt.

"Look at what has just happened in Australia. Its May Budget scrapped the 50% capital gains discount - one of the biggest tax shake-ups there in decades - and the backlash was immediate and fierce: industry uproar, economists divided, amendments forced through parliament at the last minute.

"And capital, as I never tire of pointing out, is mobile. The mere rumour of an exit tax last year was enough to send entrepreneurs for the door before the rules could change. The 24% rate, combined with the non-dom abolition, is already driving people away - I see it in my own client base. Push to 45% and you will not need HMRC’s behavioural models; you can watch it happen in real time.

08/07/2026

"HMRC's Let Property Campaign & Non-Disclosure Activities Nearly Net £550 million" - please see my new article for AccountingWEB.co.uk: https://www.accountingweb.co.uk/tax/hmrc-policy/hmrcs-let-property-campaign-nears-ps550m

's Let Property Campaign has been running for some thirteen years now, has seen some 100,000 disclosures made to date, and has no closure date.

Whilst nearly 100,000 have disclosed so far, over 15 years ago, HMRC had estimated some 1.5 million landlords had underpaid taxes... and that unpaid taxes for just 2009 & 2010 were c.£500 million!”

Interestingly, the penalty rates being achieved seem much higher when HMRC carried out compliance checks and enquiries than waiting for LPC disclosures over the same period; more than double! This should not come as a surprise though as HMRC had presumably ‘prompted’ the LPC disclosures that came thereafter. Conversely, it is expected that most of the LPC disclosures made were wholly voluntary, therefore ‘unprompted’ in nature.

The most interesting point to note here was that the total revenues secured, that’s tax, interest and penalties, were a lot higher as a result of HMRC carrying out one-to-one enquiries (or compliance checks if you prefer); more than double in 2024/25!

Readers will no doubt be aware that the LPC remains open for their clients to utilise, and that there is no official closure date. The open-ended nature of the campaign means that it is still a good time to review a client’s activities and ensure taxes on rental profits are correctly calculated, disclosed and paid etc.

The Let Property Campaign provides a relatively smooth process for professional, amateur and novice/first-time landlords who owe taxes through having let out residential properties in the UK and/or abroad. It presents the best opportunity to bring their UK tax affairs up to date in a simple way.

03/07/2026

🔔 "Finfluencers" are still at it, more so than ever it seems! Check out Jonathan Barber's (of the The Institute of Financial Accountants) latest article: https://lnkd.in/eKK9SThT

Here are some snippets-

"The convergence of social media finfluencers and sophisticated large language models (LLMs) is reshaping how accounting and tax information is consumed...

🔉 "The shift in online finfluencers may have broadened access to financial advice, but it has also introduced a significant risk for UK businesses and accountants. For many business owners, the first port of call for financial guidance is no longer a professional adviser but a search bar, a chatbot, or a 30-second video.

🔊 "SMEs are particularly exposed. Without dedicated finance teams, they can often rely on fragmented sources of information to make decisions that carry legal and financial consequences. The result is a growing gap between perceived understanding and actual compliance.

📢 "Short-form video platforms like TikTok have accelerated the spread of financial content, rewarding clarity and confidence over nuance and context. Influencers frequently present definitive answers to complex and compelling questions like ‘how to pay zero tax’, ‘what your accountant won’t tell you’, or ‘the best business structure for everyone’, with little reference to individual circumstances or regulatory constraints.

"The Financial Conduct Authority (FCA) has identified widespread non-compliance in social media financial promotions and has taken enforcement action against individuals promoting unauthorised schemes.

🔉 "The accounting profession is increasingly encountering clients who have acted on online guidance before, or even instead of, seeking professional input, with several recurring themes emerging.

- Overstated deductibility of expenses
- Simplistic incorporation strategies
- Misleading payroll and dividend advice
- VAT misconceptions

"While these examples are not inherently fraudulent; the danger lies in their presentation as universally applicable solutions to all people and all businesses. Without the oversight of a qualified accountant, these situations can be costly for businesses in more ways than one.

🔊 "For accountants, the impact is visible in practice. Clients may arrive with pre-formed strategies based on online advice, requiring correction or restructuring.

"The reputational risk for businesses should not be underestimated. Non-compliance with tax obligations can lead not only to financial penalties but also to scrutiny that affects relationships with lenders, investors and partners.

🔔 "Advisers are spending more time explaining to clients why certain widely circulated ‘tips’ do not apply. This requires clear communication skills and an ability to translate technical rules into practical guidance."

pure-tax.com

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26/06/2026

📢 Haven't posted much recently, but this one got my attention. 'CEO made junior staff create false invoices in £400k fraud' - thanks to
Jacob Grattage and Croner-i for the write-up: https://lnkd.in/emCtDyXs

If we take the politics out of this, this is routine tax fraud which we see in many tax cases where the owner-manager of a business and/or their staff give false information to cover up personal expenditure. Here, Peter Murrell from Edinburgh, was CEO of the Scottish National Party (SNP) from 2001 to 2023, and was married to former first minister of Scotland, Nicola Sturgeon between 2010 and 2025, has been found to have hidden his £400,000 shopping spree - paid for using SNP bank accounts.

Murrell was jailed for five years and three months at the High Court in Edinburgh on 23 June for embezzlement after defrauding the SNP of membership dues and contributions, and hiding his wrongdoing using fake invoices on accounting software.

🔊 If were interested in this case from a tax fraud perspective, then they could have pursued him using (Code of Practice 9), including a ContractuaI Disclosure Facility offer. See more here about COP 9: https://lnkd.in/ePepaAZ2

On the day the trial was due to start, Murrell pleaded guilty to the fraud charge. The fraud occurred over a period of 12 years from 2010 to 2022.
False invoices were created by Murrell to give the impression that the expenses he claimed were for legitimate SNP expenditure.

🔉 The court heard that in his role, Murrell was also able to make direct transfers of money from the SNP’s bank account, and he had a charge card linked to that account in his name. Murrell had direct access to the accounting system and could log items of expenditure himself, although the majority of such work was done by another staff member under Murrell’s direction, the prosecution explained; although he fed that person false information.
.. A motorhome was also bought and added to the SNP’s fixed asset register ‘but it was never used or seen by any other party member or employee’, the prosecution explained. Murrell recorded this as a 'van'.

Upon sentencing Murrell, judge Lord Young stated: ‘The manner of the embezzlement, although not particularly sophisticated, included the fabrication of invoices. You gave false information to junior members of staff to input into the accounting system. This was a calculated crime of dishonesty.

‘Let me make it clear to you, one factor in the sentence which I impose today will be to act as a deterrent to any senior officials in other large organisations who might be tempted to abuse their position in the way you did.’

Pure-Tax.com

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25/06/2026

Have you or your client received that dreaded brown-enveloped letter from , about a tax investigation, business enquiry or tax disclosure?

Are you or they looking for someone with considerable (over two decades) tax disputes and risk management experience, having worked at HMRC for over a decade, to help?

Do you or they want assistance with setting the strategy, providing clarity at each stage, expediting a conclusion and ensuring the outcome is commercial?

Then contact me at [email protected]

22/06/2026

09/06/2026

📢 HMRC arrests east London pair in TikTok/social media related tax repayments fraud projet. Thanks to Croner-i and Sara White for the write-up: https://lnkd.in/eXvTjiEW

🔊 Two men have been arrested in East London after blocked £153m in alleged fraudulent tax repayment claims; scam promoted on TikTok. The suspects allegedly used TikTok to persuade people to wrongly secure tax refunds and hand over their tax account details.

🔉 HMRC's cybercrime investigators arrested the pair during a raid last month, and subsequently released on bail. They were arrested on suspicion of fraud by 'false representation' contrary to Section 2 of the Fraud Act 2006.

No further details are known about this ongoing investigation currently, but HMRC is urging people to be cautious about any online posts claiming ‘risk free’ rewards, and is flagging the prevalence of these types of scams, saying it has ‘seen similar suspected scams across multiple social media platforms - such as Instagram and Snapchat’.

🔔 We're conscious there has been widespread mis-selling and 'too good to be true advice' from "finfluencers" online already, and we have written about this already. Take a step back and consider these supposed social media tax experts' credibility first. It follows that anyone giving out their private/tax details risks their identity being stolen and their bank account being frozen etc.

Pure Tax Investigations

04/06/2026

📢 Tax Case Judgement: builder loses CIS tax appeal at the FTT, unsurprisingly. Thanks to Croner-i and Rickie L. for the write-up.

🔔 The taxpayer opted not to tell their accountant about cash payments they made to their sub-contractors, and was unable to convince the FTT that it had taken 'reasonable care' with its tax affairs for CIS Regulation 9 purposes, making it liable for the uncollected tax amounts.

George Jarda was engaged to supervise sub-contractors for another company and, when that company ceased around 2015, he stepped into the vacuum and formed George Star Builders Ltd (GSB) as the sole director/shareholder. GSB took over most of the staff and contracts of the ceased company and appointed an accountant and bookkeeper to deal with its affairs. GSB registered for CIS as a contractor and obtained gross payment status.

Bearer cheques
In a curious move, sometime in 2017, Jarda began asking customers to pass him cheques with the payee sections left blank. The cheques went on to be cashed at a bureau and some of the money was used to pay GSB's sub-contractors. Jarda said he believed this was all above board, as the sub-contractors would then be responsible for their own tax affairs. GSB subsequently made £nil monthly returns, claiming that no payments had been made to sub-contractors...

📢 opened a Code of Practice 9 tax investigation (https://lnkd.in/ePepaAZ2) as it suspected GSB had deliberately underpaid CIS tax in those £nil periods.

Later, after an Independent Review found for HMRC, GSB appealed to the FTT.

The only matter which needed to be resolved was whether CIS Reg 9(3)(a) was met, specifically whether GSB had taken reasonable care to comply with s.61 FA2004.

🔊 The FTT found that a taxpayer taking reasonable care to meet its tax obligations would not have utilised a cheque cashing service to pay suppliers off-the-books and kept this from their advisers. No surprise!

🔊 Having become aware that there could be tax implications, a reasonable taxpayer would then look to take steps to investigate further. But Jarda seemingly chose not to do so, despite GSB having advisers who could have been consulted.

Pure Tax Investigations

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29/05/2026

Great night at India Week's gala dinner tonight.