Pure Tax Investigations

05/10/2026

📢 Wow, wasn't expecting to read this today! An accountant is charged over alleged stabbing at an HMRC raid: https://www.accountancydaily.co/accountant-charged-over-alleged-stabbing-hmrc-raid

"North London accountant accused of money laundering, false accounting, and tax evasion charged after allegedly stabbing police officer in leg during HMRC dawn raid"

🔔 An ICAEW qualified chartered accountant, Charles Charalambous, sole director of Charles Alexander & Co Ltd, in Mayfair London, has been charged with allegedly stabbing a police officer during a dawn raid by the Metropolitan Police, HMRC and the FCA... ‘wounding with intent to cause grievous bodily harm to resist arrest’.

"Charalambous was charged with participating in the activities of an organised crime group, money laundering, tax evasion, false accounting, and failure to disclose suspicion of money laundering. The Met Police said his arrest was part of a wider operation targeting a suspected organised crime group, in which more than 800 officers carried out dawn raids at 24 properties across London, Essex, Hertfordshire, Cambridgeshire and Suffolk in the early hours of 29 September. The operation resulted in 17 arrests, while searches remain ongoing at a number of the addresses."

01/10/2026

🔊 The Hidden Shift in HMRC Tax Investigations: What COP8 and COP9 Mean for You in 2026

Please take a minute to read our short, new article on HMRC Code of Practice 8 and 9 investigations. https://www.linkedin.com/pulse/hidden-shift-hmrc-tax-investigations-what-cop8-cop9-mean-amit-puri-bwcle/?lipi=urn%3Ali%3Apage%3Ad_flagship3_detail_base%3Bp5pA9yEfRraPS%2F2YbcResg%3D%3D Click through to see the full statistics and breakdowns on COP9 and COP8 Fraud Investigation Service's investigations over the recent 2025-26 year.

If you receive a letter from HM Revenue & Customs (HMRC) citing a Code of Practice 8 (COP8) or Code of Practice 9 (COP9) investigation, it is critical to understand that you are no longer dealing with a routine, front-line compliance check.

These investigations represent the sharp end of HMRC’s civil investigation and enforcement. They are handled exclusively by the Fraud Investigation Service (FIS)—a specialist directorate focused on high-value tax risks and suspected deliberate action / tax fraud.

While the total revenue yielded by these specialist civil investigations remains flat at £144 million for 2025/26, the internal dynamics have shifted:

For taxpayers, this means FIS investigators are heavily prepared, highly focused, and moving with greater velocity. Whether that's negotiating contract settlements or proceeding formally via the Tribunals.

Protecting Your Position

Whether facing the deep transactional analysis of a COP8 or the strict contractual requirements of a COP9, these investigations cannot be managed like standard tax enquiries. The financial consequences—including penalties that can reach up to 200% of the tax due for offshore matters—and the threat of public naming and shaming require immediate, tax investigations specialists intervention.

To successfully conclude an FIS investigation, taxpayers must take proactive control of the investigation and/or disclosure process, manage HMRC’s expectations with strict timelines, and ensure all submissions are handled by experienced tax investigation specialists. They should not ignore nor antagonise HMRC.

To see the full breakdown, comparative metrics, and specific statutory frameworks utilised by the Fraud Investigation Service, read our updated comprehensive guide to HMRC Code of Practice 8 and 9 Tax Investigations.

If you receive a letter from HM Revenue & Customs (HMRC) citing a Code of Practice 8 (COP8) or Code of Practice 9 (COP9) investigation, it is critical to understand that you are no longer dealing with a routine, front-line compliance check. These investigations represent the sharp end of HMRC’s ci...

18/09/2026

📢 "Accountancy firms need to stand up to finfluencers" - https://lnkd.in/epvEjVZc - A must read from Croner & Esha Amani-Cundy

"The shift to alternative advice from finfluencers and AI means firms have to work twice as hard to retain clients and win new business, and they cannot stand idly by in the face of the threat

😱 "Unregulated social media advice and AI tools are giving younger taxpayers the illusion of free technical guidance. Simply warning against the risks isn’t enough, instead traditional firms must adapt to stay relevant.

"For many it looks like a natural extension of the great ‘democratisation of knowledge’ that such digital tools afford – the perception being that they make guidance and insight more accessible and free of charge.

📣 "The reality is that such unregulated and potentially ill-informed advice, offered without personal context, is at best incomplete and at worst dangerous. Those blithely following it without professional guidance could risk an HMRC investigation, potential fines and even criminal proceedings.

"The reach of so-called finfluencers is already considerable. Consumer research from TSB just last month found 32% of respondents had acted on financial advice found on social media platforms – with six in 10 (59%) regretting it, and over half (56%) having lost money as a result, with an average loss of almost £700

"The trend is significantly higher in younger age groups. The Financial Conduct Authority (FCA) reports that nearly two-thirds (62%) of 18- to 29-year-olds follow social media influencers, 74% of whom said they trusted their advice, with nine in 10 young followers having been encouraged to change their financial behaviour.

Tax misinformation

📣 "Online tax misinformation is rife – despite HMRC’s longstanding and ongoing ‘tax avoidance: don’t get caught out’ campaign. The issue was raised by Labour MP Stella Creasy in a House of Commons debate in March, when she urged the Treasury to consult and report on tackling the harm caused by online ‘tax influencers’ and ensure anti-avoidance powers cover social media content creators.

"A big catalyst for viral tax myths is the misconception that because an online submission is accepted without an immediate query, HMRC has formally approved the figures – an experience finfluencers might then share with followers.

"But that fails to take account of HMRC’s ‘process now, check later’ approach. Errors can be identified years after filing, with financial consequences compounding rapidly with late payment interest alongside penalties.

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11/09/2026

While all of our HMRC tax investigation cases are settled without the need for a substantive Tribunal hearing, we keep abreast of Tribunal case judgements, practices and precedents. In Vadera [2026] UKFTT 1206 (TC) the Tribunal refuses a reinstatement application as the applicant had failed to take reasonable steps to monitor the appeal. The moral is that one should not play with the Tribunal's rules and test its patience. Thank you to Croner and Ben Bailey for the write-up: https://library.croneri.co.uk/cch_uk/taxtoday/wkid-202609090917080431-78086694?utm_source=linklist&utm_medium=email&utm_campaign=taxtoday-alert

📢 Here, the FTT refused an application for reinstatement of an appeal, because the appellant failed to comply with the Tribunal’s directions, reminder and unless order, and failed to provide a satisfactory explanation for the defaults too.

"The substantive appeal concerned the appellant’s entitlement to repayment of stamp duty land tax in the sum of approximately £2.8m arising from the appellant’s acquisition of an apartment. The issue for determination in this case was whether the appeal should be reinstated following its automatic strike out."

📣 In considering the merits of the reinstatement application, the FTT applied the three-stage approach described in Martland. Therefore, the FTT considered in turn, the seriousness and significance of the breach, the reasons for that breach and all the circumstances of the case.

Seriousness and significance of the breach

The appellant argued that breach was a relatively minor procedural failure consisting of a failure to confirm an intention to continue with an appeal that had never been withdrawn. HMRC submitted that the FTT had to look not only at the breach of the unless order but also the antecedent failures which led to it... The FTT therefore concluded that the relevant breach was not a single isolated omission but a sequence of failures culminating in automatic strike out.

Reasons for the breach

FTT noted that the appellant relied on three matters to explain his breach: (1) the appeal had been stayed for a prolonged period; (2) he was residing abroad; and (3) Cornerstone Tax 2020 Ltd, the appellant’s representatives, had entered administration. The FTT found that these matters explained why the correspondence did not come to the appellant’s personal attention. However, the FTT also found that the matters did not satisfactorily explain the absence of effective arrangements for monitoring substantial ongoing litigation.

All the circumstances of the case
.. appellant acted promptly once the strike out came to his attention, no hearing date was lost and that the appeal had been stayed for a substantial period... The FTT repeatedly highlighted that no replacement representative was instructed, no effective communication arrangements were established and there was no meaningful oversight of the proceedings.

Decision released: 19 August 2026 Reinstatement following automatic strike out – Failure to comply with unless order – Adviser default – Responsibility for litigation – Denton/Martland principles – Reinstatement refused – The Tribunal Procedure (First-Tier Tribunal) (Tax Chamber) Rules 2...

03/09/2026

🔔 Is the Worldwide Disclosure Facility Working? We had another look at the latest statistics and trends to see what we could learn, for the ACCA's Accounting and Business Magazine.

📣 Ten years on, the WDF is not bringing in the anticipated revenue.

🔈 The WDF initiative provides individuals who have earned income or achieved gains overseas with a streamlined opportunity to bring their UK tax affairs up to date by making a voluntary disclosure through an HMRC portal. Provided the disclosures made online are full and complete, there is no need to engage further with HMRC.

🔉 Despite a growing number of disclosures in recent years, and ongoing ‘nudge letters' on the part of HMRC, the average taxes secured by each disclosure have been reducing.

🔊 HMRC has secured just under £920m from the Worldwide Disclosure Facility to date, including taxes, statutory late payment interest and penalties. But more can and should be done.

🔈 It is positive to see consistent numbers coming out of a disclosure facility where HMRC’s one-to-many approach has been deployed, which is not as resource intensive as one-to-one enquiries. Over the past two years, HMRC has secured over £100m from each.

🔉 The number of WDF disclosures made annually (see graphic) has remained painfully low compared to the enormous volume of banking data available. As an example, the total number of WDF disclosures received in 2018 and 2019 was 16,589, but the number of offshore accounts reported to HMRC in, say, 2017 or 2018 was around three or four million. The data exponentially eclipsed the number of disclosures made and the number of nudge letters HMRC sent out.

🔊 Also, HMRC appears to continue to focus on people with much smaller levels of (un-remitted) income overseas and/or those who have not been resident in the UK for long, possibly being the low-hanging fruit. Those people accessed the Remittance Basis automatically (and for free).

🔔 Those who wait for HMRC to contact them lose the ability to make a wholly voluntary disclosure and are therefore unable to secure the minimum penalties.

📣 So, it is still a good time to review a client’s overseas activities, accounts, wealth etc, and ensure that UK taxes on investment income and gains are correctly calculated and disclosed. We secure the best possible outcome for clients, based on our robust knowledge about tax assessment time limits, the various offshore penalty regimes that apply and double-taxation relief quirks.

Please see ACCA article here:

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21/08/2026

📢 Accountancy professional bodies slate HMRC's plan for new ‘reckless statements’ offence. Thanks to Croner-i's Jacob Grattage for the article: https://lnkd.in/eiQ-jUD6

📣 "Major accountancy institutes criticise HMRC power grab, saying ‘criminal sanctions should not be used to resolve technical disputes over legislation’ "

As expected, there is strong opposition to HMRC's proposals from across the profession, saying the measure introduces unnecessary ‘uncertainty’. We are mindful that the ACCA, the Chartered Institute of Taxation (CIOT), and the Low Incomes Tax Reform Group (The Low Incomes Tax Reform Group (LITRG)), have all voiced their opposition, given the extent of HMRC’s existing powers.

📣 HMRC want to introduce a new offence for giving ‘reckless untrue statements’ in direct tax cases, because a similar offence already exists for indirect taxes, such as VAT.

🔊 Put squarely, ACCA stated: ‘Given that HMRC has these powers for indirect tax we are confused why HMRC has not provided evidence of their use and effectiveness as part of the consultation.’

🔊 The CIOT raised similar concerns, stating: ‘The government has yet to demonstrate why a new criminal offence is needed when extensive civil penalties and criminal powers already exist.’

There is widespread fear that HMRC would criminalise genuine mistakes. Understandably, a criminal liability is a serious one and so there should be no parallel to a taxpayer or professional adviser reaching a reasonable interpretation of uncertain legislation.

📢 HMRC are proposing a two-year prison sentence and an unlimited fine, which are serious sanctions which could apply to acts that merely fall short of dishonesty. In this connection, the CIOT's Ellen Milner warned: ‘If people become worried that ordinary discussions with HMRC or disclosures about uncertain tax positions could expose them to criminal sanctions, that risks discouraging the open and constructive engagement on which the tax system depends.’

Amit Puri
Managing Director
Pure Tax Investigations

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17/08/2026

📢 Some time ago we asked to tell us more about their work on Agents and Tax Advisers, specifically their "Agent Compliance Team". From experience we knew it was specialist team responsible for identifying, preventing and managing tax risks posed by Agents (such as accountants or tax advisers) but we wanted to understand it better.

HMRC have though decided that giving any more information to us would cost them too much and prejudice the work they are doing. Our understanding is that it was set up in 2012.

🔊 HMRC confirmed that that the team includes units focusing on 'Agent Standards' and 'Agents' Own Affairs' - which is why we have been seeing more letters to Agents from HMRC in the last six to twelve months. "These teams carry out a variety of compliance interventions, including "one-to-many" activities, where a single intervention or communication is directed to multiple agents or advisers at the same time, which can result in large volumes of correspondence being issued."

📣 HMRC confirmed the team now sits within 'Counter-Avoidance Directorate', across a range of HMRC offices throughout the UK, with approx. 140 staff. As expected, the team works closely with a range of HMRC directorates, particularly compliance, technical and policy teams, to identify and address risks associated with Agents.

📣 The total number of Dishonest Agent Conduct Notices issued under FA 2012 Schedule 38 Paragraph 4 from 01/04/13 to 21/04/26, has been extremely low at only '11'.

📣 The total number of Dishonest Agent Penalty Determinations issued under FA 2012 Schedule 38 Paragraph 26 has also been extremely low at only '8'. 5 of those were appealed to the Tribunal.

📣 There have been fewer than '5' File Access Notices issued under FA 2012 Schedule 38 Paragraph 7.

📣 The total number of (Dishonest) Agents whose names have been published under the naming and shaming disclosure regime was 'nil'.

Please see our article from May 2026 about the new and currently active Sanctionable Conduct regime for Agents: https://lnkd.in/eU7tbfHB

Please see our older September 2024 article for HMRC Tax Investigations Enquiries and Powers: https://lnkd.in/eae-5292

However, don't forget that many other parts of/teams in HMRC write to and pursue Agents, not just this team. What is your experience of HMRC's Agent Compliance Team?

Can we assist you or an Agent you know?

24/07/2026

📢 Recently, the long-running litigation concerning excise duty on alcohol purchased by B&M Retail Ltd in 2010-2011, was heard by the First-tier Tribunal which concluded that the taxpayer did have a "reasonable excuse" for its 'non-deliberate' failure and has set aside the entire £1.1 million penalty.

🔔 The Tribunal found that it was not realistically possible for the Appellant to obtain definitive proof of duty paid but it did take steps that were reasonably open to it in the circumstances.

The findings were determined by reference to existing findings of primary facts as well as some further evidence adduced principally around the Appellant's due diligence processes re onboarding its supplier.

📣 Interestingly, the FTT said "... 's witness was unable to identify any specific additional steps which could realistically have been taken and that HMRC was unable to establish whether duty had been paid... a feature of the market in which the Appellant operated and not a consequence of any failure on its part."

📣 Also, "I have taken into consideration all of the circumstances in which the Appellant found itself at the relevant time, including that no further practical steps were available to verify the duty status of the goods, that HMRC were unable to establish the duty position... I accept that the Appellant was taking a commercial risk in continuing to trade in those circumstances. It seems to me that to adopt HMRC's position in this case would be to impose a standard approaching certainty in circumstances where certainty was not achievable."

🔊 This post is not about the 'reasonable excuse' safeguard itself nor is it about 'deliberate' as opposed to 'non-deliberate' behaviour/actions. It is to highlight that the defence bar is relatively high because something must have stopped a person meeting their tax obligation AND have been out of their control, AND that obligation must then have been met without undue delay after the excuse ceased/ended. As one might expect there are pages and pages of legislation, published guidance and case law on the matter.

In the context of tax returns/documents being submitted to HMRC, where they omit something material which causes an inacurracy in a submission, the safeguards against those penalties are different. One must establish whether their behaviour/actions constituted: a mistake despite taking "Reasonable Care; or a mistake where Reasonable Care was not taken (i.e. being "Careless"); or perhaps "Deliberately" causing the error or withholding information causing the error.

I take this opportunity to highlight that a lot of work we do as a boutique tax disputes resolutions firm centres around penalty arguments not just the underlying taxes. Sometimes its only about the penalties. Therefore being competent in this area is very important. Spurious correspondence with HMRC simply gets clients nowhere.

We are the go-to HMRC Tax Investigation Specialists London. Defence against COP9 & COP8 Investigations, Compliance Checks & WDF & LPC

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
[email protected]
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.