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Criminal Investigations


HMRC may seek to prosecute where they suspect that an individual has committed serious tax fraud, or where a taxpayer has not adhered to the terms of a civil CDF investigation.

HMRC can only open a criminal tax investigation if they have sufficient reason to believe that there has been an underpayment of tax and that this underpayment has been deliberately and fraudulently obtained.


The criminal investigation process carries clear risks for both the client and their adviser. Tax evasion is a criminal offence (Cheating the Public Revenue) and carries the maximum prison sentence.

If you or your client have received any correspondence from HMRC that references a criminal investigation, it is imperative that you take specialist advice immediately.


Hamilton Rose can assist with quantifying the tax liabilities and will work alongside a lawyer to ensure that the process is correctly managed and, wherever possible, we will agree conditions with HMRC to encourage them to proceed on a civil basis.

We have 30 years of combined experience dealing with HMRC fraud investigations and we know how to manage the process correctly to ensure that HMRC do not obtain information they are not entitled to, that the correct amount of tax is paid and that your best interests and assets are protected.

We will ensure that you are fully supported throughout the process and give you peace of mind that any historic UK tax inaccuracies are fully resolved.