--- title: "How will Covid-19 affect Tax Disputes with HMRC?" url: https://taxdisputes.co.uk/2020/04/how-will-covid-19-affect-tax-disputes-with-hmrc/ date: 2020-04-27 modified: 2026-06-02 author: "Annabel Clarke" description: "Despite the ongoing coronavirus (COVID-19) pandemic, it is clear that HMRC will continue to pursue tax investigations and seek the enforcement of tax debts. It is therefore important to be..." categories: - "Coronavirus" - "COVID-19" - "HMRC" - "News" tags: - "Coronavirus" - "COVID-19" - "First Tier Tax Tribunal" - "HMRC Investigations" - "HMRC Tax Disputes" - "solicitors" - "Tax" - "Tax Appeal" - "Upper Tier Tax Tribunal" image: https://taxdisputes.co.uk/wp-content/uploads/2020/04/lexlaw-covid-19-HMRC-Tax-Disputes-Tax-Tribunal-London-Lawyers-1024x398.jpg word_count: 904 --- # How will Covid-19 affect Tax Disputes with HMRC? Despite the ongoing coronavirus (COVID-19) pandemic, it is clear that [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)will continue to pursue [tax investigations](https://taxdisputes.co.uk/hmrc-tax-investigations-solicitors-london/) and seek the enforcement of tax debts. It is therefore important to be fully informed as to the approach that HMRC will be adopting during this time of widespread uncertainty.   ## How will HMRC change their investigations during Covid-19? While [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)will continue to investigate tax debts during the COVID-19 pandemic, it has been reported that in some cases [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)will not request (or reiterate requests previously made for) further documents or information from taxpayers during the lockdown. In other cases [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)may temporarily suspend inquiries.  [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)have also confirmed that they will continue to send out letters during lockdown to some taxpayers who are facing the [controversial loan charge](https://taxdisputes.co.uk/2019/03/the-spotlight-shines-on-disguised-remuneration/), some of whom will need a respond to HMRC within 30 days.  ## Why have HMRC changed their approach? [HMRC’s ](https://www.gov.uk/government/organisations/hm-revenue-customs)main priority at this time is to protect individuals, businesses and the economy and therefore has prioritised work that will support businesses. Furthermore [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)now has a lot of extra work as they implement the Government’s furlough scheme.  Similarly to many other UK businesses, it is also likely that [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)have a reduced number of employees due to the pandemic and therefore, by shifting their priorities will be able to deal with the work load more effectively.  ## How have the tax tribunal adapted to COVID-19? The [tax tribunals](https://www.judiciary.uk/coronavirus-covid-19-advice-and-guidance/) have also had to make changes to allow them to still [operate during the pandemic](https://www.tax.org.uk/policy-technical/technical-news/covid-19-%E2%80%93-first-tier-tribunal-tax-chamber-practice-statements-and).  The main changes that the [First-tier Tax Tribunal](https://www.gov.uk/courts-tribunals/first-tier-tribunal-tax) in light of the Covid-19 crisis are: - extending the circumstances in which the tribunal can make a decision without a hearing;- extending the circumstances in which the tribunal can direct that a hearing be held in private. (thereby enabling the tribunal to conduct video or telephone hearings, which would otherwise be regarded as private hearings, in many more cases); - allowing the use of electronic bundles of documents during tribunal hearings; and- requiring recordings to be made of any video or telephone hearings. There will now be no physical in-person hearings to take place. Hearings will only take place by video or telephone where electronic bundles of documents will be used. The decision to extend the circumstances for on paper sessions to be made will also allow more cases to be decided on paper and therefore reduce the number of hearings.  Similar changes have also been made to the[ Upper Tribunal](https://www.gov.uk/courts-tribunals/upper-tribunal-tax-and-chancery-chamber) with the default position being that hearings will be conducted by video. Parties are also able to apply to adjourn a hearing to a date when it will be possible to hold a physical hearing.  ## How will you know if you are subject to a HMRC investigation? [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)will notify a taxpayer in writing when it commences to examine their tax affairs. Typically, if [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)starts a formal civil investigation, a letter will be sent requesting more information. For example, a taxpayer may receive a request for information on a property transaction or further information about a tax return from a local compliance audit. However, if [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)suspects [criminal VAT fraud](https://taxdisputes.co.uk/repayment-fraud/) or high amounts of tax evaded then it may commence criminal investigations. Typically, unlike for a civil investigation, [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)are unlikely to notify you at the start of the process but instead you will either be informed once you receive a letter requesting attendance to a voluntary interview under caution or when you are arrested. It is crucial that, once under review, specialist [Tax Investigation](https://taxdisputes.co.uk/hmrc-tax-investigations-solicitors-london/) Lawyers are instructed. We regularly liaise with [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)at formal meetings, agree what the scope of the disclosure should be and prepare the report on your behalf and reach a civil settlement with [HMRC](https://www.gov.uk/government/organisations/hm-revenue-customs).  We have wide-ranging experience in assisting those facing a COP 9 investigation whilst helping to navigate the rigid time-limits and strict rules. ## How long will a tax investigation last? It depends on the scope and nature of the [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)investigation. The opening letter issued by the [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)is usually a good guide on the potential length of any investigation. Some [tax investigations](https://taxdisputes.co.uk/hmrc-tax-investigations-solicitors-london/) finish after one letter; other investigations can take months with [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)consistently requesting more information; and some investigations can be extending to longer than a year if involving complex tax structures or large businesses. It is important to engage professional advice early on to minimise the length of any investigation as we identify any problems quickly and efficiently to get to the heart of the matter. ## Expert London Tax Investigation Lawyers If you need [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)[Tax Investigation](https://taxdisputes.co.uk/hmrc-tax-investigations-solicitors-london/) advice, we are available to aid you at every stage of the [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)investigate process. Members of our legal team have first-hand experience and knowledge of the internal workings of [HMRC](https://www.gov.uk/government/organisations/hm-revenue-customs). We can provide you with the very best representation in negotiations with [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)and defending all forms of [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)fraud, tax inquiry, tax fraud investigation, criminal tax evasion and [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)enquiries and investigations. Our team specialises in successfully challenging [HMRC ](https://www.gov.uk/government/organisations/hm-revenue-customs)decisions and will assist you in every aspect of the investigation. Our specialist Tax Solicitors and Barristers deliver expert technical knowledge, strong negotiation skills and respected advice, which can make a pronounced difference to eventual tax penalties, charges and liability. **We provide urgent advice and representation to clients from our unique expert team of established Tax and Duties specialist solicitors and barristers with a proven track record of delivering authoritative results. Just call us on 0207 1830 529, or email [contact@lexlaw.co.uk](javascript:;).**