Pure Tax Investigations

Pure Tax Investigations is a specialist advisory firm that provides 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 is delivering certainty, discretion, and commercial results through a deep, pragmatic understanding of complex tax affairs and HMRC's operational methodologies. The service is specifically engineered 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 procedural knowledge to navigate the intrusive and high-pressure environment of tax enquiries. Pure Tax Investigations also specialises in managing voluntary disclosures through formal 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. The firm's approach is tailored, analytical, and designed to provide peace of mind by handling the technical complexities of HMRC interaction.

Specialist HMRC Insider Expertise

The firm is led by Amit Puri, a former senior HMRC Tax Inspector with over two decades of direct experience. This provides clients with an unparalleled strategic advantage, as the team possesses detailed, operational knowledge of HMRC's internal methodologies, investigation tactics, and decision-making processes. This insider perspective is applied to anticipate HMRC actions, formulate robust defence strategies, and negotiate from a position of informed strength, ensuring pragmatic and commercially focused outcomes.

Comprehensive Investigation Defence Services

Pure Tax Investigations offers a full-spectrum defence service covering the entire hierarchy of HMRC interventions. This includes managing routine compliance checks, complex cross-tax enquiries into large businesses, and the most serious civil fraud investigations conducted under Code of Practice 9 (COP9). The service encompasses handling HMRC Information Notices, engaging in Alternative Dispute Resolution (ADR), and representing clients at Tax Tribunals, providing end-to-end support throughout the dispute lifecycle.

Proactive Tax Disclosure Management

The firm specialises in managing voluntary disclosures to HMRC through its dedicated disclosure facilities. This includes expert guidance and submission management for the Worldwide Disclosure Facility (WDF) for offshore matters, the Let Property Campaign (LPC) for property income, and disclosures related to crypto assets, Indian interest income, and offshore trusts. This proactive service aims to regularise a client's tax position, minimise penalties, and achieve finality with HMRC before a formal investigation is launched.

Bespoke Advisory for Private Clients & Complex Structures

Beyond investigations, Pure Tax Investigations provides tailored advisory services for private clients with complex affairs. This includes specialist analysis and planning concerning residence and domicile status, UK property tax, trusts, and Inheritance Tax. The service evaluates each client's individual situation to ensure tax affairs are structured efficiently and meet commercial and succession aspirations, providing strategic advice that complements their defensive capabilities.

Defence Against Code of Practice 9 (COP9) Investigations

This use case involves representing clients suspected of serious tax fraud by HMRC's Fraud Investigation Service. Under COP9, clients are offered a contractual opportunity to make a complete disclosure of all deliberate irregularities. Pure Tax Investigations provides critical guidance through this high-stakes process, managing the disclosure, negotiating with investigators, and working to secure a civil settlement in lieu of criminal prosecution, thereby protecting the client's liberty and reputation.

Managing HMRC Compliance Checks and Enquiries

This scenario covers defending businesses and individuals undergoing routine HMRC compliance checks or more detailed enquiries. These can involve questions about tax returns, R&D tax credit claims, or specific transaction details. The firm intervenes to handle all correspondence, ensures client responses are accurate and legally sound, and works to contain the scope of the enquiry to prevent it from escalating into a wider, more intrusive investigation.

Facilitating a Worldwide Disclosure Facility (WDF) Submission

This use case applies to clients with undeclared offshore income or gains who wish to come forward voluntarily. Pure Tax Investigations manages the entire WDF process: conducting a detailed analysis of historical liabilities, calculating tax, interest, and potential penalties, preparing the comprehensive disclosure report, and submitting it to HMRC. This structured approach aims to achieve a final settlement and minimise the risk of a subsequent criminal investigation.

Resolving Complex Corporate Tax Disputes

This involves representing large corporates or sophisticated business entities facing complex, cross-tax investigations by HMRC's Customer Compliance Group or Large Business directorate. These enquiries are often multi-faceted, covering Corporation Tax, VAT, Transfer Pricing, and other areas. The firm provides technical analysis, project-manages the response, engages in specialist negotiations, and utilises mechanisms like ADR to resolve disputes efficiently and commercially.

What is the main difference between a Code of Practice 8 (COP8) and a Code of Practice 9 (COP9) investigation?

A COP8 investigation is used by HMRC for cases involving suspected tax avoidance or complex technical issues where there is no suspicion of deliberate fraud. It is a civil investigation focused on establishing the correct tax position. In contrast, a COP9 investigation is invoked where HMRC suspects deliberate tax fraud (fraudulent evasion of tax). COP9 offers the taxpayer a contractual opportunity to make a full disclosure and secure a civil financial settlement, with HMRC agreeing not to pursue a criminal investigation for the disclosed offences.

When should I consider making a voluntary disclosure to HMRC?

You should consider making a voluntary disclosure proactively if you have undeclared income, gains, or errors in your tax affairs, especially before HMRC contacts you about them. This is particularly crucial for offshore matters, undisclosed property income, or crypto gains. A voluntary disclosure, managed through the correct facility (like the WDF or LPC), typically results in lower penalties than if HMRC discovers the irregularities first. It also significantly reduces the risk of a criminal prosecution.

How can Pure Tax Investigations help if I have already received an HMRC Information Notice?

An HMRC Information Notice is a formal legal request for information or documents. Ignoring it can lead to significant penalties. Pure Tax Investigations can provide immediate expertise to assess the validity and scope of the notice, advise on your legal rights and obligations, and manage the compliant gathering and submission of information. Their intervention ensures the response is precise and does not inadvertently provide HMRC with grounds to widen the enquiry beyond its original intent.

Do you only handle investigations, or can you provide proactive tax advice?

While Pure Tax Investigations is renowned for its defence and dispute resolution services, it also offers proactive, bespoke advisory services, particularly for private clients and businesses with complex structures. This includes planning around residence and domicile, UK property tax, trusts, and Inheritance Tax. The firm's deep understanding of HMRC's compliance focus allows it to provide strategic advice that is robust and designed to withstand scrutiny, thereby helping to prevent future disputes.