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HMRC Enquiries & Disputes

🛡️ Tax Investigation Accountant Brighton

Received a COP9 letter, an HMRC nudge letter, or notice of a compliance check? We provide discreet, experienced representation for HMRC tax investigations, COP9 and voluntary disclosures, the Let Property Campaign, Wealthy Team enquiries, and VAT, PAYE & Corporation Tax investigations across Brighton, Hove and beyond.

Free, confidential consultation Call 07534 476727
HMRC enquiry & investigation support
COP9 & CDF experience
Let Property Campaign disclosures
VAT, PAYE & CT enquiries
Strict confidentiality
31 years in practice
HMRC AML supervised
Why Fitzpatrick Co

Facing HMRC,
not facing it alone

An HMRC letter is designed to unsettle you. The right response is calm, well-informed, and handled by someone who deals with HMRC regularly — not a first attempt under pressure.

31 years in the profession

James Fitzpatrick has three decades of experience dealing with HMRC across enquiries, disclosures and disputes for individuals and businesses.

HMRC AML Nominated Officer

Fitzpatrick Co is directly supervised by HMRC for Anti-Money Laundering purposes — we understand HMRC's own compliance expectations from the inside, not just from the outside.

We control the correspondence

Once we're instructed, HMRC deals with us. We decide what's disclosed, when, and how — reducing the risk of an off-the-cuff answer being used against you later.

Honest about scope

Where a matter carries genuine criminal risk, we say so plainly and bring in specialist tax investigation counsel alongside our own work — we don't overstate what we can do alone.

Regulated & supervised: ✓ AAT-Licensed Practice ✓ HMRC AML Supervised

"Most people only ever deal with HMRC once in their lives — under pressure, at the worst possible time. Our job is to take that pressure off you and deal with it properly."

— James Fitzpatrick, Fitzpatrick Co
Speak to us in confidence
📞 07534 476727 📧 info@fitzpatrickco.uk 💬 WhatsApp us
What we handle

HMRC investigations & disclosures

Every case starts with a free, confidential conversation about the letter or notice you've received and what it actually means.

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HMRC Tax Investigations & Compliance Checks

Full support through an HMRC enquiry into a Self Assessment return, business accounts or a specific transaction — from the first letter to closure notice.

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Code of Practice 9 (COP9) & the CDF

Guidance through the Contractual Disclosure Facility where HMRC suspects deliberate tax fraud, including the 60-day response and the outline and full disclosure reports.

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Let Property Campaign

Voluntary disclosure of undeclared UK or overseas rental income, calculated correctly across every relevant year, before HMRC opens an enquiry of its own.

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HMRC Wealthy Team & High-Net-Worth Enquiries

Representation for individuals contacted by HMRC's Wealthy and Mid-sized Business Compliance directorate, where income, assets or offshore matters bring wider scrutiny.

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VAT Enquiries & Compliance Checks

Responding to VAT inspections and compliance checks, correcting errors before HMRC finds them, and negotiating where assessments or penalties are disputed.

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PAYE & Corporation Tax Enquiries

Handling employer compliance reviews, PAYE and benefits-in-kind enquiries, and Corporation Tax enquiries into company accounts and tax computations.

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Worldwide Disclosure Facility

Disclosing undeclared offshore income, gains or assets under the Worldwide Disclosure Facility, where HMRC's international data-sharing has increased the risk of detection.

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HMRC Nudge Letters

HMRC increasingly writes "nudge" letters based on data it already holds, without opening a formal enquiry. We assess what's actually being asked and the right way to respond.

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Code of Practice 8 (COP8)

Support with complex enquiries into tax avoidance arrangements or intricate tax affairs where fraud isn't alleged, but the matter needs careful, technical handling.

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Self-Assessment Enquiries

Full or aspect enquiries into an individual Self Assessment return — from a single queried figure to a complete review of a tax year.

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How it works

What happens next

Most clients speak to us within 24 hours of getting in touch — deadlines in this area of work are often tight.

01

Free, confidential review

Send or bring us the actual letter from HMRC. We read it properly, explain what it means in plain English, and tell you what the realistic timeline and options are.

02

Strategy & fixed-fee proposal

We agree the right route — full disclosure, a specific campaign such as the Let Property Campaign, or a robust response to an enquiry — and a clear fee before any work starts.

03

We deal with HMRC directly

All correspondence goes through us. We prepare disclosures and responses methodically, and never send HMRC anything you haven't seen and approved first.

04

Resolution

We negotiate the settlement, argue for fair penalty treatment based on genuine cooperation, and push for a closure notice so the matter is properly behind you.

Worth knowing

Time limits & penalties

General HMRC rules that shape almost every investigation and disclosure. Your own position will depend on your specific facts.

4 years

Ordinary assessment

The standard time limit for HMRC to assess additional tax where there's no suggestion of carelessness or deliberate wrongdoing.

6 years

Careless behaviour

Where an error is judged careless rather than a genuine mistake, HMRC's time limit extends to six years after the relevant tax year.

12 years

Offshore matters

A separate time limit applies to certain offshore income, gains and inheritance tax issues, regardless of behaviour.

20 years

Deliberate behaviour

Where HMRC establishes deliberate wrongdoing, or a failure to notify a liability, it can assess as far back as twenty years.

Up to 30%

Careless penalties

Penalties for careless inaccuracies are capped at 30% of the extra tax due, reduced significantly for a genuinely unprompted disclosure.

Up to 100%

Deliberate & concealed

Deliberate and concealed behaviour can attract penalties of up to 100% of the tax at stake — the single biggest reason to get early, proper advice.

This is general information current as at 2026, not advice for your specific circumstances — penalty percentages and time limits depend on the detail of each case. Please contact us before relying on anything above.

Common questions

Frequently asked questions

What is a COP9 letter and what should I do if I receive one?
Code of Practice 9 (COP9) is issued when HMRC suspects serious tax fraud. It comes with an offer to enter the Contractual Disclosure Facility (CDF), which requires you to admit whether there has been deliberate wrongdoing in exchange for HMRC not pursuing a criminal investigation into the matters disclosed. You typically have 60 days to respond. Get advice before you respond or contact HMRC — how the first 60 days are handled matters enormously.
What is the Let Property Campaign and should I use it?
It's HMRC's disclosure facility for landlords with undeclared UK or overseas rental income. Coming forward voluntarily, before HMRC contacts you, generally attracts a much lower penalty than a prompted disclosure after an enquiry has started. We calculate the correct liability across the relevant years, prepare the disclosure, and manage HMRC's response.
What is HMRC's Wealthy Team and why have I been contacted?
HMRC's Wealthy and Mid-sized Business Compliance directorate, including the Wealthy Team and the Offshore, Corporate and Wealthy unit, focuses on individuals with income over £200,000 or assets of £2 million or more. Their enquiries tend to be broader than a standard compliance check, often spanning several years and multiple income and gains sources at once.
How far back can HMRC investigate me?
Generally 4 years for an ordinary error, 6 years where behaviour is judged careless, and up to 20 years where it's judged deliberate. A separate 12-year limit applies to certain offshore income, gains and inheritance tax matters, even without an allegation of deliberate wrongdoing.
Will I go to prison for a tax investigation?
The great majority of investigations, including most COP9 cases, are resolved civilly through disclosure, assessment and penalty, not prosecution. HMRC generally reserves criminal proceedings for the most serious cases or where someone fails to cooperate with a genuine offer to disclose. Where there's a real criminal risk, we bring in specialist tax investigation counsel alongside our own work on your file.
How much does it cost to have an accountant handle my HMRC investigation?
We agree a fixed fee wherever the scope allows it, based on a free, confidential initial assessment. Where the scope is genuinely uncertain at the outset, we agree clear rates and keep you updated on cost as the case develops — no surprise bills.
Is everything I tell my accountant about a tax investigation confidential?
Yes. We're bound by professional confidentiality and by our own HMRC Anti-Money Laundering supervision, and we treat every investigation matter with strict discretion. As with any UK accountant, our one legal exception is a duty to report knowledge or suspicion of money laundering under the Proceeds of Crime Act — we'll always explain what that does and doesn't mean for your situation before we start.
Get in touch

A confidential conversation

Free, no-obligation and completely confidential. Tell us what's landed on your doormat and we'll tell you, honestly, what it means and what we'd do next.

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Location42 Brunswick Terrace, Hove BN3 1HA
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WhatsApp07534 476727
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HoursMonday – Friday, 9am – 5:30pm

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