HMRC Special Investigations

HMRC Special Investigations conduct cases using the Code of Practice 9 provisions, dealing with cases of the most serious tax evasion within their specific remit.


HMRC Special Investigations is an HMRC department, formerly known as Special Civil Investigations. Any contact from this office must be treated extremely seriously, given that they are responsible for the investigation of cases where serious tax fraud or evasion is suspected. If you receive a letter from the Special Investigations team, immediate, proactive action is absolutely vital. This will minimise the possibility of criminal proceedings being instigated.

Code of Practice 9 covers cases where HMRC suspect the most serious tax fraud. It gives taxpayers the opportunity to fully disclose irregularities in their UK tax affairs. The disclosure comes in the form of a comprehensive written report, which should be prepared by an experienced tax investigation adviser.

Detailed information on the Code of Practice 9 is available via our essential guide.

Generally these teams deal with cases where the perceived tax at risk, including interest and penalties is at least £500,000 It can be seen that tax investigations conducted by HMRC Special Investigations teams are within the highest risk category. HMRC need to be treated with utmost respect and preferably dealt with by a tax investigation specialist.


HMRC Special Investigations teams are staffed by very senior officers. This means your case will be the subject of detailed forensic analysis. It is vital that you seek representation from an adviser who has a detailed knowledge of HMRC Special Investigations work. They will guide you through the entire process ensuring that your disclosure is comprehensive and robust.


As part of the HMRC Special Investigations process you will be required to submit a comprehensive disclosure report covering up to 20 years. Any report submitted to HMRC Special Investigations will need to be accompanied by completed statement of assets and a certificate of full disclosure.

We have written dedicated pages on both of these issues, which are linked below:

Your HMRC Special Investigations disclosure will also need to include a completed certificate of all bank, building society and credit cards operated during a specified period. The period covered by the disclosure report will usually be agreed between your adviser and the HMRC Special Investigations officer conducting your case. This is otherwise known as scoping.


Following the Inland Revenue merger with Customs and Excise HMRC Special Investigations will generally have a VAT element. This is otherwise known as cross tax. In such circumstances the lead investigator will often be assisted by a VAT specialist. If you have concerns regarding VAT evasion then please take some time to read our dedicated pages on VAT investigations.


You simply cannot afford to make mistakes under the HMRC Special Investigations process. Materially false or misleading statements can result in a criminal prosecution.Do not risk your liberty for unpaid tax. Burying your head in the sand will have that inevitable consequence.


Who better to deal with HMRC Special Investigations on your behalf than an adviser who has worked at senior level within that particular department. We welcome contact from individuals, businesses and from professional advisers who are not comfortable in dealing with cases emanating from HMRC Special Investigations. These HMRC teams are by their nature very resource intensive so we are happy to act either as consultant or if requested, take over management of the case.

Get in touch

Under no circumstances should you attempt to deal with an intervention by HMRC Special Investigations alone. Contact a former senior HMRC inspector by calling Admiral Tax Investigations on 0330 999 5000.