We are highly experienced in defending clients who find themselves subject to an HMRC enquiry or investigation.

Receiving an enquiry letter from HMRC can be a worrying time, especially as investigations tend to be technical in nature. Our consultants at TT Intelligence have honed their technical expertise and defence processes to provide clients with the reassurance and assistnace they need to satisfy HMRC's requests.

Our process for tax enquiries

  • We will ask you for a copy of the enquiry letter
  • We will fully explain the nature of the particular enquiry to you 
  • We may ask you to provide documentation or other necessary information required to be able to fully defend the case
  • Each step of the way we will be in touch until a resolution is reached with HMRC 
  • The full implications of that resolution will be thoroughly explained to you    


Here's a summary of the most common tax enquiries TT Intelligence assist with:

1. S9A

S9A Notices are the most common type of enquiries, HMRC can use these to check a single aspect or the full entries on your self assessment tax return.

2. Code of Practice (COP) 9

COP9 enquiries are raised where HMRC suspect tax fraud. These are the most serious tax enquiries HMRC can embark upon and must be dealt with as such. HMRC reserve the right in a COP9 enquiry to pursue a criminal investigation with a view to prosecution if they deem it necessary and appropriate.

HMRC will not normally tell you the fraud they suspect, so it is down to you to come clean. It is where your disclosure of any anomaly is absent or incomplete that HMRC may pursue criminal action.

If you receive a COP9 enquiry it is likely that your accountant has never dealt with one before so it important that you engage a specialist, such as ourselves, who can either take the entire case, or work hand in hand with your current advisor to bring the enquiry to as swift and satisfactory conclusion as possible.

2. Code of Practice (COP) 8

COP8 enquiries are raised when COP9 is not used and apply to cases involving bespoke avoidance and fraud but do not necessarily involve the suspicion of fraud at the outset. HMRC reserve the right to escalate the case to COP9 if serious fraud is established.

Although lesser than a COP9 enquiry, COP8 enquiries should also be dealt with with the upmost of care. We can work the entire case, or work hand in hand with your accountant to bring matters to as swift and satisfactory conclusion as possible.

Opportunities to make Disclosure to HMRC

Lichtenstein Disclosure Facility (LDF)

The Lichtenstein Disclosure Facility (LDF) is being closed at the end of 2015. The LDF enables disclosure of irregularities connected with offshore bank accounts and structures to be disclosed to HMRC on beneficial terms.

A summary of the benefits of using the LDF include an immunity for prosecution, HMRC agree not to go back beyond 6 April 1999 (they can usually go back 20 years, more for Inheritance Tax), and a simplified rate of tax rather than using the actual rates in force at the time.

The LDF is likely to be replaced by something much less generous, so if you have offshore irregularities that need to be disclosed it is important you come forward and register with HMRC for the LDF before 31 December 2015.

For further information about our Tax Enquiry and Defence services please contact us.

What our clients say about us

“TT Intelligence have been an invaluable source of support to my business. Their attention to detail and professional, efficient manner has been excellent, allowing a seam-free service to my clients. ”

Accountancy Practice Client