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Tax Enquiries, Closure Notices and Discovery Assessments

Master the legal framework and best practices for managing HMRC scrutiny with confidence

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A one-day course

pdf Download:   Course Outline

Framework for Tax Enquiries

  • Legal basis for opening and conducting enquiries (TMA 1970, FA 1998, FA 2003, etc.)
  • Conditions and statutory time limits for valid enquiries across different taxes (Income Tax, Corporation Tax, SDLT, VAT)

HMRC’s Powers and Procedures

  • Enquiry powers: requirements for valid enquiry, service issues, scope and extent of enquiry
  • Data-gathering capabilities, including use of “Connect”, third-party notices, and financial institution notices
  • Information requests and document production requirements

 Special Investigation Codes

  • COP8: High-value or complex tax avoidance cases
  • COP9: Contractual Disclosure Facility (CDF) for suspected tax fraud with opportunity for voluntary disclosure
  • Discussion on when used, scope and obligations imposed on HMRC / taxpayer.

Closure Notices & Discovery Assessments

  • When and how to obtain closure notices via the First-tier Tribunal
  • Legal criteria for valid discovery assessments including nature of requirements / consequences concerning categorisation of behaviour: innocence, carelessness, or deliberate behaviour
  • Statutory limitation periods

Handling Enquiries Effectively

  • Risk assessment, strategic planning, and documentation
  • Adviser-client relationship management
  • Legal options and best practices for responding to HMRC letters and meetings

Litigation and Case Law Insights

  • Review of cases (e.g., Raftopoulou, White v HMRC, Beckwith)
  • Importance of compliance with procedural requirements
  • Case law on scope and validity of enquiries

 Information Rights and Privilege

  • Legal Professional Privilege (LPP) and limitations on HMRC access
  • Key rulings affirming the scope of LPP and audit confidentiality (e.g., DAC Beachcroft LLP [2018])
  • Guidance on how and when to assert privilege

The lead trainer for this Part 8 Claims course was called to the Bar in 1995, he brings a wealth of experience gained from a distinguished career that spans both the independent Bar and senior positions within leading City and international law firms. He has also worked in New York and the Cayman Islands. His practice is dispute-led, with a strong emphasis on the intersection between legal, commercial, and tax issues.

He is a specialist in tax law and its associated fields, including commercial chancery, equity, company law, cryptocurrency and digital assets, partnerships, insolvency, and professional negligence. He advises on complex investigations and appears regularly for corporate entities, individuals, and HMRC at both trial and appellate levels. Much of his work involves high-value or technically challenging disputes, often arising from cross-border transactions or cases with voluminous documentation. He also has experience advising and representing individuals in matters involving allegations of fraud, including criminal tax investigations.

The trainer was awarded a Ph.D. (University of London) in Tax Law relating to intellectual property and its exploitation. He is co-author of Taxation of Intellectual Property (Bloomsbury Publishing), A Practical Guide to Tax Disputes (Lexis) and Internet Business (Commerce and Tax) (Jordans).

He is ranked as a Leading Practitioner in Chambers UK Bar 2025 and has particular expertise in areas such as corporate structures, partnerships, intellectual property, trusts, and insolvency, allowing him to provide strategic, commercially attuned advice across a broad range of contentious and non-contentious matters.

He appears regularly in courts and tribunals across the UK, including London, Manchester, and Edinburgh, acting both as sole counsel and as part of larger legal teams.

The course co-presenter is a dedicated tax specialist 'Pupil Barrister' with a rapidly developing practice encompassing a broad range of domestic and international tax matters. He read law at the age of 17 and was a Vice Chancellor International Scholar at Cardiff University. He was called to the Bar by the age of 21. Alongside his Bar studies he was working under a pre-eminent tax silk in the country.

Participants will leave the seminar with:

  • A firm understanding of how HMRC initiates and conducts tax enquiries.
  • Knowledge of the statutory rights and obligations of taxpayers.
  • Practical tools for managing client compliance, responding to enquiries, and protecting sensitive information.
  • Strategic insights into minimizing litigation risk and handling disputes effectively.

This Tax Enquiries, Closure Notices and Discovery Assessments course would be benefit all;
  • Tax professionals
  • Legal advisers
  • Accountants
  • Compliance officers

This intensive one-day seminar provides a comprehensive exploration of HMRC’s approach to tax enquiries, closure notices, and discovery assessments.

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