DJC-Consulting: Tax Investigation Specialist Advice & Assistance

HM Revenue & Customs enquiries - advice and assistance

Tax enquiries are a stressful experience for anyone unlucky enough to be on the receiving end. Whether you're the target of the unwelcome attention of HM Revenue & Customs (HMRC), or an adviser acting for a client in that position, David Cunliffe can provide the specialist advice and assistance you may need.

The specialist help available includes:

Tactical guidance in enquiries into Tax Returns or business accounts by HMRC.
Advice and support to whatever level is required during a particularly difficult or complex tax enquiry.
Advice on how to deal with Special Civil Investigations (formerly Special Compliance Office) if they become involved in an investigation (see below).
Guidance on preparing tax enquiry disclosure reports where this is appropriate.
Ensuring that the risk of prosecutions is reduced as far as possible in the most serious cases.
Assistance in negotiating the best possible settlement, with the lowest level of penalties, in an HMRC enquiry.

Special Civil Investigations (SCI)

SCI is HMRC's investigation head office and it is staffed by the best investigators in the Department - see the page on SCI for more information. It was formed in 2005 from the Inland Revenue's Special Compliance Office and the Law Enforcement Investigation section of HM Customs.

Be wary of the possible involvement of SCI in investigations by local tax offices, whether overt or in the background. It is understood that HMRC have been obtaining an increasing amount of information about offshore funds in recent years and apparently innocuous enquiries by local tax offices may have been prompted by information held by HMRC about offshore investments. Failure to disclose such investments in an enquiry could lead to a prosecution for tax evasion. It should be noted that Liverpool SCI has a large number of officers handling offshore enquiries.

When SCI take over an investigation, they usually issue one of their Codes of Practice (8 or 9), both of which offer protection from prosecution. If neither of those Codes of Practice has been issued, do not attend a meeting with an officer of SCI without first taking specialist advice.

A knowledge of how SCI operate is essential to ensure that any investigation by SCI staff is handled correctly. Most non-specialist advisers do not possess the relevant experience or skills. David Cunliffe has been representing clients under SCI's scrutiny since 1988 and has the thorough knowledge required to protect anyone who is investigated by SCI. David now provides these services through Qdos Consulting.