Pure Tax Investigations

About Pure Tax Investigations

Pure Tax Investigations is a specialist advisory firm providing expert defence and resolution services for businesses, entrepreneurs, and private clients facing scrutiny from HM Revenue & Customs (HMRC). The firm operates as an independent, expert buffer between clients and the tax authority, offering robust representation during all forms of tax disputes. Its core value proposition lies in delivering certainty, discretion, and commercial results through a deep, pragmatic understanding of complex tax affairs and HMRC's operational methodologies. The service is specifically designed for those undergoing routine compliance checks, complex cross-tax investigations into large corporates, or serious civil fraud investigations under Codes of Practice 8 and 9. Led by Amit Puri, a former senior HMRC Tax Inspector with over 20 years of experience, the team leverages insider knowledge to navigate the intrusive and high-pressure environment of tax enquiries. Pure Tax Investigations also specialises in managing voluntary disclosures through facilities like the Worldwide Disclosure Facility (WDF) and the Let Property Campaign (LPC), aiming to regularise clients' tax positions while preserving wealth and achieving finality.

Features of Pure Tax Investigations

Specialist HMRC Investigation Defence

Pure Tax Investigations provides robust, specialist defence for clients undergoing HMRC enquiries. The team acts as an independent intermediary, managing all communications and negotiations with HMRC. This feature involves a detailed analysis of the client's position, strategic planning to challenge HMRC's assertions, and pragmatic advocacy to resolve disputes efficiently, thereby shielding clients from direct pressure and intrusive questioning.

Expertise in Serious Civil Fraud Procedures (COP9/CDF)

The firm possesses specific, high-level expertise in managing investigations under HMRC's Code of Practice 9 (COP9) and the accompanying Contractual Disclosure Facility (CDF). This feature entails guiding clients through the critical process of responding to allegations of serious tax fraud, with the objective of securing a civil settlement and avoiding criminal prosecution. The service includes preparing the Outline Disclosure and managing the entire disclosure process to HMRC's Fraud Investigation Service.

Comprehensive Tax Disclosure Management

Pure Tax Investigations offers end-to-end management of voluntary tax disclosure campaigns. This feature covers the preparation and submission of disclosures under key HMRC facilities such as the Worldwide Disclosure Facility (WDF) for offshore matters and the Let Property Campaign (LPC) for undisputed rental income. The process ensures disclosures are complete, accurate, and presented in a manner that mitigates potential penalties and interest charges.

Cross-Tax Corporate & Business Enquiry Handling

The service includes managing complex, comprehensive compliance checks aimed at large corporate entities and businesses. This feature involves coordinating responses to HMRC enquiries that span multiple taxes (e.g., Corporation Tax, VAT, PAYE), often involving detailed forensic examination of business records and transactions. The team provides a structured, commercial approach to these in-depth investigations to minimise disruption and achieve a definitive resolution.

Use Cases of Pure Tax Investigations

Defence Against a Code of Practice 9 (COP9) Investigation

A business owner receives a letter from HMRC opening a COP9 investigation, indicating suspicion of serious tax fraud. Pure Tax Investigations is engaged to act as the buffer. The specialists manage all interaction, advise on the contractual disclosure process, prepare the necessary Outline Disclosure, and negotiate with the Fraud Investigation Service to secure a civil financial settlement, thereby averting the risk of criminal proceedings.

Voluntary Disclosure via the Worldwide Disclosure Facility (WDF)

An individual with previously undisclosed offshore income or gains seeks to regularise their tax position with HMRC. Pure Tax Investigations steps in to manage the entire WDF process. This involves calculating the historical tax liability, preparing the formal disclosure report, corresponding with HMRC, and negotiating the lowest possible penalties within the facility's framework to bring the matter to a close.

Managing a HMRC Compliance Check into a Large Corporate

A large corporate entity is subject to a comprehensive, cross-tax compliance check by HMRC, involving extensive requests for information. Pure Tax Investigations is appointed to coordinate the response. The team reviews all documentation, liaises with HMRC officers to scope the enquiry, provides technical analysis on complex transactions, and works towards a commercial settlement that limits financial exposure and reputational damage.

Regularising Property Income through the Let Property Campaign (LPC)

A landlord with multiple rental properties has not fully declared rental income to HMRC. They engage Pure Tax Investigations to make a voluntary disclosure under the LPC. The firm calculates the undeclared profits over the relevant years, prepares the disclosure, advises on the penalty mitigation factors, and submits the full package to HMRC to settle the outstanding liabilities under the favourable terms of the campaign.

Frequently Asked Questions

Is a COP9 tax fraud investigation serious?

Yes, a Code of Practice 9 investigation is a serious civil procedure undertaken by HMRC's Fraud Investigation Service when they suspect serious tax fraud has occurred. The process is designed to secure a financial recovery of tax, interest, and penalties on a civil basis. While the alternative could be a criminal investigation with a view to prosecution, COP9 offers a contractual route to disclose and settle, provided the taxpayer cooperates fully under the terms of the Contractual Disclosure Facility.

What is the difference between COP8 and COP9 investigations?

Code of Practice 8 (COP8) investigations are used by HMRC for cases involving suspected avoidance or sophisticated tax planning where fraud is not suspected. They are civil enquiries often concerning complex technical interpretations. Code of Practice 9 (COP9), conversely, is explicitly for cases where HMRC suspects serious tax fraud from the outset. COP9 involves the Fraud Investigation Service and includes the Contractual Disclosure Facility, which provides an opportunity for the taxpayer to admit fraud and seek a civil settlement.

What is the Worldwide Disclosure Facility (WDF)?

The Worldwide Disclosure Facility is a permanent HMRC initiative that allows UK taxpayers to disclose previously undeclared UK tax liabilities relating to offshore assets, income, or gains. It provides a standardized process for making a voluntary disclosure to correct past omissions. Using the WDF can result in higher penalties than some legacy campaigns but offers a finalised route to settle liabilities and regularise one's tax position with HMRC.

Why should I use a specialist instead of dealing with HMRC directly?

Engaging a specialist firm like Pure Tax Investigations provides critical advantages. Specialists act as an expert buffer, handling all stressful communications and negotiations. They possess in-depth knowledge of HMRC's procedures, tactics, and settlement frameworks, which can lead to more favourable outcomes. Their experience allows for strategic management of the case, ensuring disclosures are robust and correctly presented, which helps to control the scope of the enquiry, mitigate penalties, and achieve certainty more efficiently.