Strategic Handling of HMRC Enquiries - 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 a formal enquiry has even begun.

In this highly practical and strategically focused face-to-face seminar, expert speaker Jivaan Bennett of Temple Tax Chambers will use realistic case studies, facilitated discussion and practical exercises to guide participants through the full lifecycle of an HMRC investigation - from first contact through to settlement.

Working collaboratively, you will explore how to anticipate HMRC’s tactics, protect client positions and influence outcomes. The in-person format will provide opportunities to test different approaches, compare professional perspectives and discuss the practical challenges that arise during contentious HMRC engagements.

Designed for accountants, tax advisers, lawyers and in-house tax professionals involved in managing enquiries or disputes, this seminar will be 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. It is an interactive, strategy-led session designed to sharpen professional judgment, improve decision-making under pressure and enhance your ability to manage difficult interactions with HMRC effectively.

What You Will Learn

Through case studies, group exercises and facilitated discussion, the seminar will cover:

Early Engagement - Setting the Strategic Tone

• Responding to initial HMRC contact without inadvertently narrowing the client’s options
• Distinguishing a routine enquiry from a potentially high-risk investigation
• Gathering and assessing information before committing to a position
• Avoiding early-stage mistakes that could weaken the client’s long-term position
• Deciding when to engage, seek more time or challenge HMRC’s assumptions

Understanding HMRC Behaviour & 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 individual officers
• Identifying when HMRC is shifting from an enquiry to an enforcement mindset
• Using behavioural insight to anticipate HMRC’s next steps and shape responses

Disclosure, Privilege & Tactical Control

• Navigating disclosure obligations without unnecessary overexposure
• Protecting legal professional privilege when working in mixed advisory teams
• Managing risks arising from internal communications and documentation
• Framing disclosures strategically to support a coherent narrative
• Distinguishing informal requests from the use of formal information powers, including Schedule 36

Building & Executing a Tactical Response Plan

• Developing a coherent strategy aligned with the client’s objectives
• Timing responses to preserve flexibility and maximise leverage
• Coordinating legal, accounting and forensic specialists effectively
• Managing parallel risks, including civil penalties, criminal exposure and reputational damage
• Deciding when to concede, resist or reframe an issue

Preparing Clients for Contentious HMRC Tactics

• Preparing clients for interviews, information requests and site visits
• Managing client expectations and behaviour under pressure
• Responding to aggressive or persistent HMRC approaches
• Protecting clients from missteps that could escalate the dispute
• Maintaining credibility while defending the client’s position robustly

Resolution & Settlement Strategy

• Evaluating settlement options and litigation risk
• Structuring negotiations to achieve the best available outcome
• Deciding when to settle and when to litigate
• Using Alternative Dispute Resolution effectively
• Closing enquiries while minimising future exposure