Tax Enquiry Info.

Specialist Investigations

The Specialist Investigations (SI) branch of HMRC was rebadged in December 2008.  It operates HMRC's Code of Practice 9 (cases of suspected serious fraud) and COP 8 (tax avoidance). It has evolved from a long line of similar units: Special Civil Investigations (SCI); Special Compliance Office (SCO); Enquiry Branch (EB); Special Office; Board’s Inquiry Office (BIO); National Investigation Section (NIS); Special Investigation Section (SIS) etc.

Specialist Investigations incorporates some smaller special units (e.g. Labour Provider Unit - LPU) and its teams are based in each of the UK’s major cities.  It is considered the elite investigation arm of the tax authority and is usually staffed by highly trained, very experienced, high-flying investigators.  SI inspectors are considered in HMRC to be the best of the best.

Whilst SI has a remit to deal with new, unusual and complex situations it also has an informal brief to only take up cases where the likely “yield” (tax, interest and penalties) is expected to be a minimum of £500,000.  Many of HMRC’s largest prosecutions also started in Specialist Investigations.

Where SI is involved the case is likely to be very serious, very large and usually complex: at least in HMRC’s eyes.  Such enquiries can be very damaging; especially as many SI cases involve them approaching 3rd parties (e.g. banks, business suppliers, customers, ex-employees, internet service providers etc).

SI investigators have small case loads and ample support staff (including qualified accountants and computer forensic experts), allowing them to devote considerable resource to each case.  Dealing with a Specialist Investigations enquiry without your own specialist support can be dangerous (partly due to the risk of Criminal Prosecution) and very expensive (as the tax and penalties bill is likely to be much higher than necessary).  Penalties can be up to 100% of the extra tax they say is due.

Not all Specialist Investigations cases produce penalties, and a small number do not produce any extra tax.  But persuading the hard bitten SI investigators of this, and more crucially gathering and presenting the evidence to do so, is a difficult task but one which we at Lynam Tax have devoted our professional lives to.