HMRC fraud barristers in London.
Public Access HMRC fraud counsel for London taxpayers and their accountants — COP9 investigations, Contractual Disclosure Facility disclosures, civil tax fraud and criminal tax prosecutions.
Specialist HMRC fraud counsel for London taxpayers and advisers
Clerk and Counsel is a clerking agency that places specialist hmrc fraud barristers on HMRC fraud matters affecting clients in London and across Greater London and the South East. Instructions come in from individual taxpayers, accountants and in house tax teams, and from any law firm in the region needing specialist HMRC fraud counsel to sit alongside its own team.
London is the centre of the UK financial services, property investment and cross border trade economy, all sectors where HMRC Fraud Investigation Service COP9 investigations, MTIC prosecutions and offshore disclosure work are most concentrated. That economic profile drives a steady flow of HMRC fraud enquiries, assessments and tribunal appeals through London, and it is the work that panel counsel handle day in and day out.
Every instruction is placed on a written fixed fee where the shape of the work allows. Members of our panel cover the full spread of HMRC fraud work relevant to London clients, from a short written opinion on a discrete statutory point through to full representation at the First-tier Tax Tribunal and, where the case warrants it, the Upper Tribunal and higher courts.
Local courts and tribunals
London HMRC fraud work sits across three venues: HMRC Fraud Investigation Service opening meetings and civil disclosure work at HMRC offices, First-tier Tribunal appeals from linked civil assessments at Taylor House, and criminal prosecutions at Southwark Crown Court and the Central Criminal Court. POCA restraint and confiscation applications are heard alongside the criminal case.
- First-tier Tribunal Tax Chamber, Taylor House, 88 Rosebery Avenue, London EC1R 4QU
- Southwark Crown Court, 1 English Grounds, London SE1 2HU
- Central Criminal Court (Old Bailey), London EC4M 7EH
- Upper Tribunal Tax and Chancery Chamber, Rolls Building, London
Case management hearings and short interlocutory applications are now routinely listed on video, which keeps travel costs off the tax case budget and means panel counsel can be placed on London matters wherever their diary is based. For substantive hearings counsel travels to the listed venue.
Typical HMRC fraud instructions from London
Code of Practice 9 investigations
COP9 opening meetings, Contractual Disclosure Facility scoping and outline disclosure.
Contractual Disclosure Facility
CDF acceptance, outline disclosure documents, full disclosure reports and settlement negotiation with FIS.
Civil tax fraud and deliberate behaviour
Discovery assessments alleging deliberate behaviour, extended time limits and penalties up to one hundred per cent.
Criminal tax prosecutions
Cheating the public revenue, fraudulent evasion of income tax and VAT, and MTIC criminal prosecutions.
Restraint and confiscation
POCA restraint orders, confiscation proceedings and third party interests arising from tax fraud.
Cross border and offshore
Requirement to correct penalties, offshore asset disclosures and use of DOTAS and DAC6 information.
Fixed fee HMRC fraud advice and representation
Every fee is agreed in writing before any work begins. A written opinion on a discrete HMRC fraud point typically runs between seven hundred and three thousand pounds plus VAT depending on complexity and document volume. Drafting a Notice of Appeal to the First-tier Tax Tribunal usually sits between eight hundred and two thousand five hundred pounds plus VAT.
Hearing fees run from around one thousand pounds plus VAT for short case management hearings up to three thousand five hundred pounds plus VAT for a full day tribunal appeal at junior level, with refreshers for longer cases. Silks are quoted separately. Longer HMRC enquiries with rolling disclosure are quoted stage by stage rather than as a single fixed fee, so the London client always knows the position on cost before the next stage begins.
HMRC fraud barristers in London, common questions
What is a Code of Practice 9 investigation?
COP9 is HMRC Fraud Investigation Service procedure for suspected serious tax fraud. HMRC offers the taxpayer a Contractual Disclosure Facility, under which full civil disclosure of tax fraud is exchanged for immunity from criminal prosecution for that conduct.
Can I instruct a London HMRC fraud barrister on Public Access?
Yes. London taxpayers and their accountants can instruct BSB Public Access qualified counsel directly for COP9 opening meetings, CDF acceptance advice, outline disclosure and the full disclosure report.
Should I accept the Contractual Disclosure Facility?
That decision is time critical, personal to the taxpayer and depends on the facts of the alleged fraud. Panel counsel advise on whether to accept or reject the CDF, the scope of disclosure and the implications of denial.
Where are HMRC fraud prosecutions heard in London?
Criminal prosecutions for cheating the public revenue, fraudulent evasion of income tax and VAT and MTIC fraud are heard at Southwark Crown Court and Central Criminal Court. Restraint and confiscation proceedings under POCA sit alongside the criminal case.
What are typical fees for London HMRC fraud counsel?
COP9 opening meeting attendance and initial advice typically runs between two and five thousand pounds plus VAT. Full disclosure reports and settlement negotiation are quoted stage by stage. Criminal defence hearing fees are quoted separately by counsel and often differ between junior and QC level.
Do you cover POCA restraint and confiscation?
Yes. Panel counsel handle POCA restraint orders, confiscation proceedings, third party interest challenges and the interaction between civil settlement and confiscation.