Pure Tax Investigations

About Pure Tax Investigations

Pure Tax Investigations is a premier, specialist firm dedicated to resolving complex and high-stakes tax disputes between businesses, entrepreneurs, and private clients and HM Revenue & Customs (HMRC). The firm acts as an independent, expert buffer, providing robust defence and strategic guidance during some of the most stressful financial encounters an individual or company can face. Their core mission is to alleviate pressure, provide certainty, and secure the best possible commercial outcome for their clients. Led by Amit Puri, a former senior HMRC Tax Inspector with over two decades of experience, the team offers an insider's perspective on HMRC's methodologies. This unique vantage point is crucial when navigating serious civil investigations like Code of Practice 9 (COP9) for suspected fraud or Code of Practice 8 (COP8) for complex avoidance, as well as managing voluntary disclosures and routine compliance checks. Their value proposition lies in a tailored, pragmatic, and discreet approach that combines deep technical knowledge with a clear understanding of the client's personal and commercial aspirations, ultimately working to preserve wealth and provide peace of mind.

Features of Pure Tax Investigations

Specialist Ex-HMRC Leadership

The firm is spearheaded by Amit Puri, a former senior HMRC Tax Inspector. This provides clients with an invaluable strategic advantage, as the team operates with a first-hand understanding of HMRC's internal processes, investigative priorities, and negotiation tactics. This insider knowledge is applied to anticipate HMRC's moves, craft compelling responses, and develop effective defence strategies that are grounded in the reality of how tax investigations are conducted.

Comprehensive Tax Investigation Defence

Pure Tax Investigations offers end-to-end representation for the full spectrum of HMRC enquiries. This includes defending clients against serious, in-depth civil investigations under COP9 and COP8, managing complex cross-tax enquiries into large corporates, and handling routine compliance checks. Their approach is robust and tailored, ensuring every client interaction with HMRC is managed professionally to mitigate risk, reduce potential penalties, and control the scope of the investigation.

Proactive Tax Disclosure Management

Beyond reactive defence, the firm specialises in facilitating voluntary tax disclosures through HMRC's formal campaigns and facilities. This includes managing disclosures under the Worldwide Disclosure Facility (WDF) for offshore matters and the Let Property Campaign (LPC) for rental income. They guide clients through the process of correcting historical inaccuracies proactively, which can often result in more favourable terms compared to errors discovered by HMRC during an investigation.

Bespoke Client-Centric Advisory

Every engagement is treated with a highly personalised and pragmatic approach. The team begins by listening intently to understand the unique complexities of each client's financial affairs and personal concerns. They then evaluate the situation from multiple angles—legal, commercial, and personal—to provide clear, bespoke advice. This client-centric ethos ensures solutions are not only technically sound but also aligned with the client's broader business goals and need for discretion.

Use Cases of Pure Tax Investigations

Defence Against COP9 (Fraud) Investigations

When a business owner or entrepreneur receives a COP9 letter from HMRC's Fraud Investigation Service, it indicates suspicion of serious tax fraud. This is a critical situation requiring expert handling. Pure Tax Investigations steps in to manage the entire Contractual Disclosure Facility (CDF) process, providing a robust defence aimed at settling the matter on a civil basis, thereby avoiding criminal prosecution, while negotiating the best possible financial settlement.

Navigating Complex COP8 Enquiries

Clients facing a Code of Practice 8 investigation are typically involved in complex tax avoidance arrangements or have affairs of significant complexity. The firm uses its deep technical expertise to analyse HMRC's challenges, prepare detailed technical arguments, and negotiate with specialist HMRC units. Their goal is to resolve these highly technical disputes efficiently, minimising disruption and financial exposure for the client.

Voluntary Disclosure for Unreported Income

A landlord with undisclosed rental income or an individual with unreported offshore gains can use Pure Tax Investigations to make a voluntary disclosure through campaigns like the Let Property Campaign or Worldwide Disclosure Facility. The firm manages the entire process—from calculating historical liabilities and preparing the disclosure report to negotiating with HMRC—ensuring compliance is achieved with mitigated penalties and reduced stress.

Managing Corporate Compliance Checks

For medium to large businesses undergoing a comprehensive HMRC compliance check into corporation tax, VAT, or PAYE, the firm provides essential specialist support. They act as the central point of contact with HMRC, manage information requests, ensure responses are accurate and contained, and work to bring the enquiry to a swift and favourable conclusion, protecting the company's reputation and resources.

Frequently Asked Questions

Is a COP9 tax fraud investigation serious?

Yes, a Code of Practice 9 investigation is extremely serious. It is initiated by HMRC's Fraud Investigation Service when they suspect serious tax fraud from the outset. The process is designed to secure a financial recovery (tax, interest, and penalties) on a civil basis. While the primary aim is civil settlement, the underlying suspicion of fraud means the process is intensive, and the risk of criminal prosecution remains if the terms of the Contractual Disclosure Facility are not followed correctly, highlighting the need for expert representation.

What is the difference between a tax investigation and a tax disclosure?

A tax investigation is typically reactive, initiated by HMRC when they suspect an error or deliberate wrongdoing. It involves HMRC leading the enquiry. A tax disclosure, conversely, is a proactive process led by the taxpayer to correct a past mistake before HMRC discovers it. Pure Tax Investigations manages both: defending clients during HMRC-led investigations and guiding them through voluntary disclosure facilities, which often results in lower penalties and a more controlled process.

Why is having an ex-HMRC specialist advantageous?

Having a specialist like Amit Puri, who previously worked as a senior HMRC inspector, provides a critical strategic edge. This experience offers deep insight into HMRC's operational mindset, internal guidelines, and negotiation strategies. It allows the team to anticipate HMRC's approach, communicate effectively using the correct terminology and protocols, and build realistic strategies that align with how HMRC caseworkers and investigators are likely to assess and settle cases.

Can you help with enquiries not related to fraud or avoidance?

Absolutely. Pure Tax Investigations manages all types of HMRC compliance checks and enquiries, ranging from relatively simple queries about a tax return to comprehensive, cross-tax examinations into large corporate entities. Their expertise ensures that even routine enquiries are handled efficiently and correctly from the start, preventing them from escalating into more serious, wide-ranging investigations and alleviating significant administrative pressure from clients.