Protect yourself from the costs of an HMRC investigation
Our Tax Investigation Service covers our professional fees if you are selected for an enquiry by HMRC, it ensures that you do not have to simply concede to their demands without adequate defence from a professional advisor.
HMRC Tax Investigation Service
Professional representation fees for a tax enquiry can escalate even in cases where no mistake has been made and it is eventually agreed that there is no further tax to pay.
The average cost of a HMRC enquiry is in excess of £3,200.
We can’t prevent an enquiry, but we can make sure you have the resources for a strong defense if one arises.

Service summary
When you subscribe to our service we are able to make a claim against our insurance policy held with Professional Fee Protection in respect of our fees incurred (up to £100,000 per claim unless otherwise indicated) when we defend a client who is subject to any of the following events:
A Full Enquiry
This is a thorough investigation into all aspects of a self-assessment tax return. HMRC will conduct a detailed review of all relevant books and records supporting the return’s entries. This process includes issuing a formal notice under S9A/S12AC TMA 1970 or paragraph 24(1) Schedule 18 FA 1998.
An Aspect Enquiry
This is where HMRC reviews specific parts of a self-assessment tax return. It may involve checking certain entries, verifying records, or ensuring tax treatment is correct. A formal notice under S9A/S12AC TMA 1970 or paragraph 24(1) Schedule 18 FA 1998 will be issued.
A Business Inspection Notice
This occurs when HMRC exercises its authority to inspect business premises, assets, goods, and records. Approval is required from an “Authorised Officer” or the First-tier Tribunal. An Inspection Notice will be issued under Schedule 36 paragraph 12(2) FA 2008, which may permit a short-notice or unannounced visit.
VAT/PAYE/CIS/CJRS/NMW Compliance Visit
This is a routine compliance check covering PAYE, VAT, CIS, CJRS, or National Minimum Wage. If professional representation is needed and the client cannot handle it alone, our involvement may be required.
VAT Disputes
This arises when HMRC challenges the accuracy or completeness of a VAT return. The dispute may concern how VAT has been applied or the amount due.
PAYE/NIC/CIS Disputes
This involves an HMRC challenge regarding PAYE, NIC, or CIS returns. The dispute typically relates to how the regulations have been applied or the amount owed.
Employment Status Dispute
This is where HMRC argues that an individual classified as self-employed should have been treated as an employee under PAYE regulations.
IHT Cover
This applies when our involvement is needed following the submission of an IHT return for an estate or trust. The indemnity limit for this cover is £5,000.
Gift Aid Inspections
This occurs when HMRC reviews a registered charity’s Gift Aid Scheme to ensure compliance with regulations.
Partners/Directors Cover
If a partnership or limited company joins, we may cover an enquiry into the personal tax returns of partners, directors, and their spouses. This does not cover rental income exceeding £50,000 per annum or other business activities. We must be the tax return agent at the time of enquiry.
Application for a Judicial Review
This is a formal application to the Administrative Court challenging an official decision when no other legal remedy is available. The indemnity limit for this cover is £15,000.
Code of Practice 8 Investigations
This applies when HMRC Specialist Investigations conduct a review under Code of Practice 8. The indemnity limit for this cover is £15,000.
IR35 Status Check
This occurs when HMRC requests confirmation of whether a client falls within the scope of IR35.
IR35 Disputes
This is where HMRC states a client should be subject to IR35 legislation following a PAYE Compliance Visit or a notice issued under paragraph 24(1) Schedule 18 FA 1998. The dispute concerns whether the legislation applies.
Interventions Cover (Informal Enquiries)
This applies when HMRC contacts a taxpayer via letter or phone to clarify aspects of a self-assessment return. It does not involve a formal statutory notice and is not covered under any other section of this policy.

Additional benefits
As a subscriber to our Tax Investigation Service you benefit from access to a free client legal helpline available 24/7, 365 days a year.
The helpline gives you direct access to support from legally qualified advisors who are available 24/7, 365 days a year from one of the UK’s largest law firms. The features include:
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Ability to contact the team about any commercial UK legal problem including but not restricted to:
- Commercial litigation and dispute resolution
- Employment contracts/restrictive covenants, disciplinary/grievance issues and unfair dismissal
- Property and landlord/tenant queries
- Pensions
- Health and safety - Unrestricted access to the service 24/7, 365 days a year
- Legal support on HMRC ‘unannounced’ visits
Arrange your protection today
To discuss adding our Tax Investigation service to your schedule of services please complete the form opposite.
If you already have this service with us, it will be automatically renewed on April 1st.