Criminal Investigations

HMRC’s criminal investigation policy highlights key aggravating factors that may lead to prosecution, including:

• Organised criminal activity targeting the tax system or systematic frauds that threaten the tax base.
• Individuals in positions of trust or responsibility.
• Misrepresentation, falsified documents, or deception in tax avoidance schemes.
• Deliberate concealment, conspiracy, or corruption.
• Use of false or forged documents.
• Breaches of import/export prohibitions and restrictions.
• Money laundering, particularly involving professionals such as accountants or solicitors.
• Repeat offences or a history of civil tax disputes.
• Theft, misuse, or destruction of HMRC documents.
• Threats, assaults, or impersonation of HMRC officials.
• Links to wider criminal activity, either domestic or international.

Once a criminal investigation has been initiated, transferring the case to the civil regime can be extremely difficult, though not impossible.

Where a criminal investigation is pursued, we can assist in quantifying the tax liability. We work with solicitors who are knowledgeable in this area, to not only determine payments, but potential outcomes and to mitigate the case according to the circumstances.

If you are subject to a HMRC dawn raid, whether at your home or business, we can provide support, and introduce you to specialist lawyers.

If you are facing an HMRC criminal investigation, contact Berwick Tax for guidance and support.