HMRC Criminal Investigation: Tax Expert Witness UK

HMRC pursues criminal investigation where the alleged fraud is serious, there is strong evidence, and prosecution is in the public interest, typically involving deliberate, substantial tax evasion. The HMRC Fraud Investigation Service leads criminal investigations, with tax expert witnesses producing CrPR Part 33 compliant expert reports challenging the prosecution's financial reconstruction.

Tax expert witnesses in criminal tax cases work alongside forensic accountants, the forensic accountant addresses the financial numbers while the tax expert addresses the technical tax analysis. This complementary approach is frequently the most effective strategy in complex criminal tax proceedings.

POCA proceedings often run alongside or following criminal tax prosecution, with the benefit calculation relying on the same forensic reconstruction. Expert challenge of HMRC methodology at the criminal stage can also inform POCA benefit arguments.