On 26 January 2023 HM Revenue & Customs announced that, as of 1 January 2023, it has nine live Corporate Criminal Offenses investigations for the failure to prevent the facilitation of tax evasion, with a further 26 investigation opportunities under review. These live and potential investigations cover 11 different business sectors including software providers, labor provision, transport, accountancy and legal services.

Taxpayers have the right to appeal HMRC’s decisions to the Tax Tribunal in most circumstances. In reality, many find the appeal process too arduous, time consuming and risky; resulting in taxpayers conceding or settling matters with otherwise good prospects of success. We expect that the recommendations of the Tax Law Review Committee, if implemented, will improve taxpayers’ access to justice and level the playing field between taxpayers and HMRC.