Tax Disclosures and HMRC Investigations

Strategic Advice on Tax Disclosures to HMRC

CTM advises individuals and businesses on tax disclosures to HMRC arising from errors, irregularities or suspected non-compliance. We act in serious and high-risk matters, including disclosures involving VAT, direct tax, and cases where HMRC is already conducting, or is likely to commence, an investigation.

Tax disclosures require careful strategic judgment. Poorly handled disclosures can increase exposure, escalate matters unnecessarily, or undermine a taxpayer's position in later enquiries or Tribunal proceedings.

When a Tax Disclosure May Be Required

We advise on disclosures arising from circumstances including:

• historic VAT errors or irregular accounting
• VAT input tax claims connected with disputed supply chains
• Undeclared or incorrectly declared income or profits
• errors identified during HMRC enquiries or investigations
• pre-emptive disclosures to manage risk before HMRC intervention

Each situation is assessed on its own facts, including whether a disclosure is necessary, advisable, or capable of being limited.

Types of Disclosure

CTM Law advises on and, where appropriate, manages disclosures including:

• voluntary disclosures to HMRC
• disclosures made during ongoing HMRC investigations
• Code of Practice 9 (COP9) and serious fraud cases
• VAT disclosures linked to denied input tax or assessments
• disclosures made alongside settlement negotiations

We advise not only on the content of a disclosure, but on whether the chosen disclosure route is appropriate in the circumstances.

Our Approach to Disclosures

Our approach to tax disclosures is controlled and strategic:

• assessing whether a disclosure is required at all
• identifying the correct scope of any disclosure
• limiting unnecessary admissions or exposure
• coordinating disclosure with wider dispute strategy
• engaging with HMRC at the appropriate level
• protecting the client's position in any subsequent enquiry or appeal

Disclosures are not treated as a compliance exercise. They are handled as part of an overall risk-management and litigation strategy.

Relationship with HMRC Investigations and Appeals

Tax disclosures often sit alongside, or lead into, HMRC investigations, VAT assessments, penalties and Tribunal appeals. CTM Law advises with these downstream risks firmly in mind, including the potential for dispute, settlement or litigation.

Where matters escalate, we continue to advise and represent clients through HMRC correspondence, negotiations and, where necessary, Tax Tribunal proceedings.

Who We Act For

• company directors and shareholders
• owner-managed businesses
• individuals facing serious HMRC scrutiny
• professional advisers seeking specialist support in complex disclosures

Our work is focused on higher-risk matters where experience, judgment and careful handling are critical.