Pure Tax Investigations

Pure Tax Investigations is an essential, specialist defence service for businesses and entrepreneurs facing scrutiny from HM Revenue & Customs (HMRC). When you receive an HMRC letter, a compliance check, or a serious investigation notice, the immediate necessity is for expert, robust protection. This service acts as your critical, independent buffer, managing all communication and negotiation with HMRC on your behalf. Led by Amit Puri, a former senior HMRC tax inspector with over 20 years of direct experience, the team possesses the insider knowledge and pragmatic approach absolutely required to navigate high-stakes tax disputes. The core value proposition is certainty and peace of mind during inherently stressful and intrusive processes. Whether it's a routine enquiry, a complex Code of Practice 9 (COP9) fraud investigation, or a voluntary disclosure, Pure Tax Investigations provides tailored, commercial advice designed to protect your wealth, resolve the dispute efficiently, and safeguard your commercial aspirations. Their focus is not just on defence but on delivering clear, bespoke strategies that address your specific concerns, making them a non-negotiable partner for any serious tax matter.

Specialist HMRC Investigation Defence

This is a fundamental feature providing an essential, independent layer between you and HMRC. The team, led by ex-HMRC inspectors, manages the entire process from the initial HMRC letter to final settlement. They handle all correspondence, data requests, and meetings, employing deep procedural knowledge to build a robust defence, challenge inaccuracies, and negotiate optimal outcomes, thereby shielding you from direct pressure and potential missteps.

Expertise in Serious Civil Investigations (COP9 & COP8)

Navigating a Code of Practice 9 (COP9) investigation for suspected fraud or a Code of Practice 8 (COP8) enquiry into complex avoidance is a critical necessity. Pure Tax Investigations has the specific, proven expertise to guide clients through these intensive procedures. This includes managing the Contractual Disclosure Facility (CDF) under COP9, ensuring correct legal procedures are followed, and formulating strategic disclosures to secure civil settlements over criminal prosecution.

Comprehensive Tax Disclosure Management

Proactively managing tax disclosures is a vital service to regularise your affairs and avoid investigations. The team expertly handles disclosures under key HMRC campaigns like the Worldwide Disclosure Facility (WDF) for offshore matters and the Let Property Campaign (LPC) for rental income, as well as disclosures for crypto assets, Indian mutual funds, and other complex income sources. This ensures disclosures are complete, accurate, and presented to minimise penalties.

Bespoke Advice for Private Clients & Businesses

Understanding that every client's situation is unique, this feature delivers tailored, pragmatic tax advice beyond just investigation defence. It covers complex private client areas like Residence & Domicile, Inheritance Tax planning, and property tax, as well as business-specific issues like R&D tax credit enquiries and corporate criminal offence (CCO) compliance. This holistic approach is necessary to structure affairs efficiently and meet long-term commercial and succession aspirations.

Responding to an HMRC Compliance Check or Enquiry

Receiving an HMRC enquiry letter is a pressing concern that demands immediate, expert attention. Pure Tax Investigations steps in to manage the entire process, from interpreting the scope of HMRC's questions and gathering the necessary information to formulating precise, strategic responses. This prevents clients from inadvertently providing misleading information and helps contain the enquiry, transforming a stressful situation into a professionally managed procedure.

Managing a Code of Practice 9 (COP9) Fraud Investigation

If HMRC suspects tax fraud and opens a COP9 investigation, the stakes are extremely high, with the risk of criminal prosecution. This use case is critical for securing a civil settlement. The specialists guide the client through accepting the CDF contract, conducting a meticulous disclosure of all deliberate conduct, and negotiating with the Fraud Investigation Service to achieve a financial settlement, thereby avoiding criminal charges.

Making a Voluntary Tax Disclosure

For individuals or businesses with undisclosed tax liabilities—from offshore income, rental profits, or crypto gains—making a voluntary disclosure is a necessary step to become compliant. Pure Tax Investigations identifies the correct disclosure facility (e.g., WDF, LPC), prepares a comprehensive disclosure report, calculates the tax, interest, and penalties, and liaises with HMRC to secure the best possible terms, often reducing penalty levels significantly.

Defending Against an HMRC Information Notice

When HMRC issues a formal Information Notice under its statutory powers, compliance is legally mandatory, but the scope can be contested. This use case involves expertly reviewing the notice for validity and proportionality, challenging it at tribunal if necessary, and managing the compliant production of information. This ensures clients do not face penalties for non-compliance while protecting them from overly broad and intrusive HMRC requests.

What is the first thing I should do if I receive an HMRC investigation letter?

The absolute first step is to seek specialist advice immediately and not to contact HMRC directly. Do not ignore the letter. Forward it to a tax investigation specialist like Pure Tax Investigations. They will assess the seriousness of the enquiry, explain your rights and obligations, and develop a strategic response plan. Early intervention is crucial to prevent miscommunication and manage the direction of the investigation from the outset.

How does your experience as former HMRC inspectors benefit clients?

This insider experience is a critical advantage. It provides deep, practical knowledge of HMRC's internal procedures, operational priorities, and the mindset of case officers. This allows the team to anticipate HMRC's next moves, communicate effectively using the correct terminology, and negotiate from a position of strength and understanding. It ensures your case is presented in the most compelling way HMRC expects and respects.

What is the difference between a compliance check and a COP9 investigation?

A compliance check is a routine HMRC review to check the accuracy of a tax return or claim; it is not an allegation of fraud. A Code of Practice 9 (COP9) investigation is a serious civil investigation into suspected tax fraud, where HMRC offers the opportunity to make a disclosure under the Contractual Disclosure Facility to avoid criminal prosecution. The latter is far more serious and requires immediate specialist representation.

Can you help if I need to make a disclosure for crypto taxes or offshore income?

Yes, managing complex disclosures is a core service. For crypto assets, offshore income (e.g., from Indian mutual funds), or undisposed rental profits, the team will identify the correct disclosure facility—such as the Worldwide Disclosure Facility (WDF)—and guide you through the entire process. This includes calculating historic liabilities, negotiating the appropriate penalty level, and preparing the full disclosure report to bring your affairs into compliance with HMRC.