Tax Investigations

“Kingsley Napley LLP has carved out a niche in criminal tax investigations and litigation, drawing on broad expertise in corporate criminal defence to advise clients on the spectrum of tax fraud cases."

Legal 500 UK 2020

A tax investigation by Her Majesty’s Revenue and Customs (HMRC) could have serious implications for you and your business, potentially resulting in severe financial penalties or even criminal proceedings. Our team of expert tax lawyers has a proven track record of successfully defending both individuals and companies in civil and criminal HMRC investigations in the UK and overseas.

Enforcement activity by HM Revenue and Customs (HMRC) is at its highest for several years as successive governments have pledged to ‘clamp down’ on tax evasion and avoidance. New civil and criminal powers have emboldened HMRC, with record numbers of tax investigations and prosecutions being brought. 

HMRC has renewed targets to prosecute wealthy individuals and corporates and is focussing on both UK and off-shore tax evasion. Those who are considered to be “professional enablers” such as accountants, solicitors  and promoters of tax avoidance schemes are in the firing line.  HMRC is increasingly resorting to coercive measures in order to obtain tax related information, including search and seizure and dawn raids.  Tax investigations are regularly pursued in parallel with related money laundering proceedings under the Proceeds of Crime Act 2002 (POCA).

We have acted over many years for a variety of individuals and businesses who have found themselves subject to an HMRC investigation.  This includes representing those subject to investigations regarding the alleged evasion of income tax, corporation tax, VAT (including Missing Trader/Carousel frauds) as well as investigations into tax avoidance schemes (including film investment schemes, pension schemes, patent investment schemes, and schemes investing in contracts for difference). 

In the event of a “crisis situation” for example following arrest(s) or dawn raid(s),  we are able to provide immediate advice and assistance, including attendance at the police station and advice on the scope and legality of search warrants.  

We understand the impact a criminal investigation can have on your professional and personal life and have a good track record of resolving matters before charges are brought wherever possible.  

We work closely with other specialist professionals (for example, forensic accountants and tax counsel), in order to persuade HMRC to resolve potential tax disputes in the cheapest and least stressful way for clients,  be that through the tax tribunals, civil proceedings and/or settlements.  In the event of criminal prosecution, both we and our associated professionals will ensure the strongest possible defence is advanced at court. 

What clients and directories have said

Leading practice in the representation of individuals in regulatory investigations or enforcement actions, drawing upon significant strength in employment, criminal and white-collar law to offer a complete service in the area. Highly experienced in cases involving issues such as insider trading and mis-selling of products. Also assists individuals under investigation for alleged market manipulation and anti-competitive behaviour."

Chambers UK 2020 – A Client’s Guide to the UK Legal Profession

Unique perspective on tax from the point of view of premier league litigators."

Legal 500 UK 2020

Absolutely well suited for handling litigation for a high net worth client base."

Chambers & Partners, High Net Worth Guide, 2019

I believe their strength lies in their meticulous attention to detail and the intelligence of the individuals employed by that firm. I could not imagine a better law firm."

Chambers and Partners 2018

Excellent performance: timely and reassuring."

Chambers and Partners, 2017 

They are very knowledgeable about the law, and very skilled at representing individuals. They have tremendous depth of understanding of the law and are extremely good at working with co-counsel and developing the facts of the case."

Chambers UK, A Clients Guide to the UK Legal Profession, 2017


Regarded as one of the best financial crime firms"

Chambers High Net Worth Guide 2020

They're one of the firms that is right at the top of the scale. They're very experienced in handling the big cases. They're extremely well resourced and I've never had anything other than a good experience with them."

Chambers UK 2020 – A Client’s Guide to the UK Legal Profession 

Louise Hodges is a leading light in the market generally and David Sleight has established himself as force to be reckoned with. Both are user friendly, practical, knowledgeable and totally committed to their clients."

Legal 500 UK 2020

Honestly, they are one of the only firms who can represent individuals in tricky financial cases."

Chambers & Partners, High Net Worth Guide, 2019


Read Louise Hodges' and Caroline Day's Chapter 'Witness Interviews: The UK Perspective'  in GIR's Practitioner's Guide to Global Investigations

Tax Investigations Insights

View all


Beware the hidden cost of furlough abuse

Fraud in the time of COVID-19 - The law enforcement response

The Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion: Two years on

AML: HMRC flexes enforcement muscle to the tune of £7.8 million

Wine as an investment – the wine merchant’s risk

HMRC turns to companies to police tax evasion

HMRC takes on off-shore tax evasion

Will the new corporate offence of failure to prevent tax evasion and enhanced international tax transparency change the landscape for tax investigations?

Failure to prevent tax evasion? Responsibility shifted from HMRC onto companies

Holding Corporates to Account: Criminal Liability for Failure to Prevent Facilitation of Tax Evasion

Corporate Crime Q&A: The new corporate offence of failure to prevent tax evasion

Privilege, Confidentiality and the Challenge of Modern Technology

Bahamas succumbs to OECD pressure to implement the Common Reporting Standards

United Arab Emirates - the latest "tax haven" to sign up to enhanced tax transparency

HMRC continue to clampdown on aggressive tax avoidance schemes

Budget 2017 – 35 “New” ways to tackle tax avoidance and evasion

What the Autumn Statement means for tax evasion and avoidance

Tackling Tax Evasion – Finance Act 2016 establishes new criminal offences

Criminal Finance Bill: legislative action to back up political commitments

Launch of Office of Financial Sanctions Implementation: understanding, implementing and enforcing sanctions

Tackling Tax Evasion – Finance Bill establishes new criminal offence

"Relentless in pursuit of tax evasion and avoidance”: HMRC sets out plan to 2020

Public Account Committee hauls Google and HMRC over the coals

New Fraud Taskforce - A step in the fight against fraud or political posturing?

MPs question HMRC’s response to tax evasion, the hidden economy and criminal attacks

HMRC proposals for tackling off-shore tax evasion seriously flawed

Anti-Money Laundering: under review

No place to hide: HMRC shines a light on tax havens

Close Load more

Skip to content Home About Us Insights Services Contact Accessibility