Should I get an accountant or tax investigation specialist for an HMRC enquiry?

A straightforward compliance check on one figure is often fine with your existing accountant. Enquiries involving Code of Practice 9, suspected fraud, offshore matters, or multiple tax years usually need a specialist with dedicated enquiry experience, working alongside or instead of your accountant.

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Do this first

Identify which code of practice or type of check HMRC has opened.

If the reply date on your letter is within 14 days, call 020 3441 1258 rather than waiting, or check the reply to an enquiry you have already sent.

Key facts

When an accountant usually suffices
Single-issue checks, straightforward record requests, minor error corrections
When a specialist matters more
Code of Practice 8 or 9 cases, suspected deliberate behaviour, offshore or multi-year disclosures
Regulation
This practice is regulated by ICAEW, ACCA and AAT
Statutory basis for the enquiry
Taxes Management Act 1970 for the enquiry itself; Schedule 24 FA 2007 for penalties
Appeal route
HMRC internal review, then the First-tier Tribunal (Tax)

The short answer, explained

Not every HMRC letter needs a specialist. A routine query about one expense claim or a single figure on your return is often well within your existing accountant's day-to-day work.

The picture changes once behaviour, penalties, multiple years, or offshore matters come into play. That is where enquiry-specific experience starts to matter more than general compliance skill.

The rule behind it

HMRC enquiries are opened and conducted under the Taxes Management Act 1970, whatever their complexity. What varies is the seriousness of the case, signalled by which HMRC unit and code of practice apply.

A Code of Practice 8 letter usually deals with tax avoidance arrangements, while Code of Practice 9 is used where HMRC suspects serious fraud and offers the Contractual Disclosure Facility instead of prosecution. Both carry higher stakes than a standard compliance check.

Penalties under Schedule 24 Finance Act 2007 depend heavily on how behaviour is classified and negotiated during the enquiry. That negotiation, and how records and explanations are presented, is where specialist enquiry experience tends to make a measurable difference to outcomes, even though we cannot promise any particular result in your case.

What this means for a limited company director

As a director, an enquiry can touch both your company's corporation tax position and your own Self Assessment return, particularly around dividends, director's loans and benefits in kind. That overlap is exactly where general accounting knowledge and enquiry-specific knowledge diverge.

If your accountant already handles your compliance well but has limited enquiry experience, bringing in specialist support alongside them, rather than instead of them, often works better than switching entirely.

What this costs you

Specialist enquiry support typically costs more per hour than routine compliance work, reflecting the depth of negotiation and technical argument involved. Weighed against potential penalty differences, it is often proportionate for anything beyond a simple check.

This is why tax investigation insurance, included as standard with our Growth plans, matters. It covers professional costs of defending an enquiry without the fee itself becoming a barrier to getting proper representation — see /fees for what is included.

Common mistakes to avoid

Do not assume any accountant can handle any enquiry equally well. Compliance and enquiry defence are different skills, and this practice is regulated by ICAEW, ACCA and AAT precisely because standards and scope of work matter.

Avoid waiting until a case has escalated significantly before bringing in specialist support. Early involvement usually gives more options than joining after key positions are already set.

Do not choose based on cost alone for a serious case. A cheaper response that mishandles behaviour classification or evidence can cost far more in penalties than the fee saved.

What to do next

  1. Identify which code of practice or type of check HMRC has opened.
  2. Ask your accountant honestly whether they have handled cases at this level before.
  3. Bring in specialist support for Code of Practice 8, Code of Practice 9, or multi-year cases.
  4. Check whether tax investigation insurance already covers the professional costs involved.

Where we can help

Sources

About the author

Waqas Sagar ACA FCCA FMAAT, Managing Director. 18+ years advising UK directors on HMRC enquiries, supported by a team with over 100 years' combined experience.

Reviewed: 16 September 2026 · Next review: 16 March 2027

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Should I get an accountant or tax investigation specialist for an HMRC enquiry? is handled by the same team at Accotax London Limited, 12 London Road, Morden, London SM4 5BQ. We deal with HMRC compliance checks for limited company directors across Morden, Wimbledon, Mitcham, Sutton, Croydon, Kingston and central London, and by video call for companies anywhere in the UK.

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