Responding to Tax Investigations - A Definitive Guide for Professional Advisors

Training Provider: MBL Seminars
Course Level: Intermediate


With HM Revenue & Customs dramatically increasing the number of tax investigations, and the Crown Prosecution Service saying there will be a five-fold increase in criminal prosecutions to include complex tax scheme cases, this course is most timely.

The course explores the vast array of powers HMRC can exercise when conducting a tax investigation and how taxpayers and their professional advisers should respond to them.

In addition to serving information notices under Schedule 36 of the Finance Act 2008 where underpayment of tax is suspected, HMRC can also obtain production orders and search warrants in cases where there is a criminal investigation.

How should a taxpayer and his professional adviser respond when served with an information notice, production order or search warrant in cases where HMRC is conducting a civil or criminal investigation into a taxpayer's affairs?

What You Will Learn

A blizzard of questions will need to be answered in a very short space of time.

* To what information does the information notice or production order apply?
* In what form should the information be produced?
* Ought documents to be redacted in any way?
* Should production of some or all of the material to be resisted on the grounds of confidentiality or legal professional privilege?
* Should the information notice, production order or search warrant be challenged? If so, what sort of challenge can be brought, and in which forum?
* Who pays for the time and effort involved when complying with, or challenging, the notice or order?
* What can the professional adviser tell a taxpayer when an information notice or a production order has been served?
* Can a solicitor or accountant continue to act for the taxpayer after an information notice or production order has been served?
* Does service of a production order have any impact upon the ability of an accountant to continue with preparation of company accounts or an audit?
* Does the existence of a production order trigger any disclosure obligations on the part of the professional adviser to the enforcement authorities or the financial markets?
* How can the taxpayer encourage HMRC to bring the civil or criminal investigation to an end?
* In a criminal investigation, how much information about the taxpayer is it sensible to disclose?
* How can the taxpayer seek to persuade HMRC to accept a civil settlement instead of prosecution?
* Attendance at this course will enable you to answer these questions.

Speaker: Jonathan Fisher QC, Devereux Chambers is listed as a leading barrister specialising in cases involving proceeds of crime (money laundering, confiscation & civil recovery), fraud (civil and criminal), tax investigations and litigation, corporate crime and financial markets regulation. He is described in Legal 500 and Chambers & Partners Directories as "<i>a financial crime and revenue expert...</i>", "<i>learned and astute, a highly intelligent silk</i>", "<i>great gravitas when appearing in high-value cases where the stakes are high</i>", "<i>brilliant at money laundering and confiscation matters.</i>", "<i>highly respected for his advisory work on money laundering, proceeds of crime, VAT fraud and taxation matters</i>" and "<i>something of an expert in confiscation and the Proceeds of Crime Act 2002</i>". In addition, he is a Chartered Tax Adviser and Fellow of the Chartered Institute of Taxation, accredited Trusts and Estates Practitioner (STEP), Visiting Professor at the London School of Economics and General Editor of Lloyds Law Reports: Financial Crime.


Please see course description for details.


  • Hours 3
  • Price £240.00
  • Learning Mode Classroom-based
  • Type Structured
  • Online Assessment No

Areas of Law

Scheduled Dates

  • Start Date 11 Sep 2014
  • Duration 3 hours
  • Ref S19812
This training has already started or has finished.

Additional Information

Venue: London

Time: 14:00 - 17:15

Subscribers to the MBL Season Ticket scheme are entitled to 50% discount or greater with a SmartPlan.


  • Greater London