Strategic Handling of HMRC Investigations - From Early Engagement to Settlement

Introduction

HMRC investigations are becoming increasingly sophisticated, data-driven and assertive. For advisers, the difference between a controlled resolution and a prolonged, high-risk dispute often lies in the earliest decisions made - sometimes before formal enquiries even begin.

In this highly practical and strategically focused new virtual classroom seminar, expert speaker Jivaan Bennett of Temple Tax Chambers will use various case studies to guide you through the full lifecycle of an HMRC investigation - from first contact through to settlement - equipping you with the tools to anticipate HMRC tactics, protect client positions and influence outcomes.

Designed for accountants, tax advisers, lawyers and in-house tax professionals who are involved in managing enquiries or disputes, this session is particularly valuable for those advising clients in contentious situations or seeking to strengthen their strategic approach to HMRC engagement.

This is not a technical lecture on tax law. Instead, it is a real-world, strategy-led session designed to sharpen judgment, improve decision-making under pressure and enhance your ability to manage contentious interactions with HMRC effectively.

What You Will Learn

This live and interactive session will cover the following:

• Early Engagement - Setting the Strategic Tone
• How to respond to initial HMRC contact without inadvertently narrowing options
• Identifying when an enquiry is routine vs. high-risk from the outset
• Strategic use of information gathering before committing to a position
• Avoiding common early-stage mistakes that weaken long-term outcomes
• Deciding when to engage, delay or challenge HMRC assumptions
• Understanding HMRC Behaviour and Escalation Dynamics
• How HMRC structures and approaches different types of investigations
• Recognising escalation triggers (and how to avoid or control them)
• Managing interactions with different HMRC teams and officers
• When and how HMRC shifts from enquiry to enforcement mindset
• Using behavioural insight to anticipate next steps and shape responses
• Disclosure, Privilege and Tactical Control
• Navigating disclosure obligations without overexposure
• Protecting legal professional privilege in mixed advisory teams
• Managing internal communications and documentation risks
• Strategic framing of disclosures to support your narrative
• Handling informal requests vs. formal powers (Schedule 36 and beyond)
• Building and Executing a Tactical Response Plan
• Developing a coherent strategy aligned with client objectives
• Timing responses to maximise leverage and flexibility
• Coordinating multi-disciplinary teams (legal, accounting, forensic)
• Managing parallel risks (civil penalties, criminal exposure, reputational issues)
• Knowing when to concede, resist or reframe the dispute
• Preparing Clients for Contentious HMRC Tactics
• Coaching clients for interviews, information requests and site visits
• Managing client expectations under pressure
• Dealing with aggressive or persistent HMRC approaches
• Protecting clients from missteps that can escalate disputes
• Maintaining credibility while robustly defending positions
• Resolution and Settlement Strategy
• Evaluating settlement options and litigation risk
• Structuring negotiations for optimal outcomes
• When to settle vs. when to litigate
• Managing Alternative Dispute Resolution (ADR) effectively
• Closing enquiries while minimising future exposure

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.