Pure Tax Investigations

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.

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]