Micheal Filiou Tax Disputes and Investigations

At Micheal Filiou, we're here to help. We understand the urgency and complexity of these situations, and our experienced team is dedicated to getting you out of the HMRC "brown envelope" hole quickly and efficiently.

What is HMRC Tax Investigation?

HMRC conducts regular checks to ensure everyone pays their fair share of taxes. These checks, known as tax investigations or Section 9A enquiries, typically occur when they suspect a potential underpayment.

A small percentage of tax checks are done randomly, so they do not automatically mean the investigated taxpayer has committed any offences. However, most of the time, they are usually due to some irregularity in your tax records or accounts with accompanying consequences depending on the reasons for their behaviour and other factors.

The go-to HMRC tax specialist

Feeling overwhelmed by an HMRC notification, tax challenge or need to make a disclosure?

We offer clear explanations, efficient action, and personalised support every step of the way.

Our objective, quite simply, is to reduce the burden of a tax investigations, handle all communication with HMRC, and work tirelessly to achieve the most favourable resolution.

We will support you throughout, being at the end of the phone to answer any questions you have.

We are HMRC tax specialists and our experienced team will take the fight off your hands.

Tax mistakes happen. But with Micheal Filiou, the stress doesn’t have to.

Our proven track record and expertise ensure you receive the support and clarity you deserve. We understand how HMRC work and have the expertise to confidently handle any case, leaving you feeling assured and empowered.

Let us navigate the complexities while you regain peace of mind.

Contact us now for your free consultation.

Types of Tax Enquiries

Code of Practice 9 (COP 9)

HMRC Compliance Check

Worldwide Disclosure Facility

Let Property Campaign (LPC)

Compliance Checks and Investigations for VAT

View our Services

Personal Tax

Income tax, Capital Gains Tax, Inheritance Tax inquiries.

Voluntary Disclosures

Proactively address tax errors and minimise penalties.

Serious Fraud Investigations

COP8 and COP9 investigations

Employment Taxes

PAYE and National Insurance irregularities

Business Tax

Corporation Tax, VAT, R&D credit checks

COVID-19 Support

Enquiries into payments received or overclaimed

Tax Appeals

Represent you at the Tax Tribunal to challenge HMRC decisions.

Alternative Dispute Resolution

Explore settlement options with HMRC outside of court.

Frequently asked questions

HMRC identifies undeclared property income by gathering data from various sources, including the Land Registry, deposit protection schemes, letting agents, and financial institutions. This data is then analysed using sophisticated algorithms to identify potential inconsistencies in tax reporting. Once potential risks are identified, HMRC may initiate a compliance check or issue a nudge letter to the taxpayer.
Receiving a nudge letter from HMRC warrants prompt action, even if you believe your tax affairs are in order. Ignoring the letter could lead to penalties if discrepancies are later discovered. Engaging a tax specialist is recommended to assess your situation and determine the appropriate course of action. If a disclosure is required, seeking professional assistance can ensure its completeness and accuracy, potentially mitigating penalties and limiting the number of years to disclose.
If you suspect you may need to make a disclosure but haven't received a nudge letter, proactive action is beneficial. Voluntary disclosures typically attract lower penalties. For further guidance, feel free to contact us for a free consultation.
Regardless of whether the disclosure is prompted or voluntary, the first step is to register your intention with HMRC. If you've received a nudge letter, this should be done within 30 days of the letter's date. For unprompted disclosures, act quickly to secure lower penalties. Upon registering the disclosure, HMRC will confirm receipt and provide a Disclosure Reference Number (DRN). You'll have 90 days from this date to prepare and submit the disclosure, including tax due, interest, and penalties. HMRC expects liabilities to be paid upon submission. If this poses difficulties, inform HMRC upfront to arrange a payment plan.

The length of time HMRC can investigate tax affairs varies, with a maximum of 20 years. This period can be reduced depending on the taxpayer's behaviour and whether tax returns have been filed previously.

  • With filed returns but unintentional inaccuracies: HMRC's lookback period is 4 years if reasonable care was taken and 6 years if not.


  • Without filed returns: HMRC's lookback period is typically 20 years, even if the inaccuracies are unintentional. However, it can be reduced to 4 years if a valid excuse exists.

  • Will I be charged a penalty?

HMRC will assess penalties for taxpayers who have not accurately reported their property income. However, penalties may not apply if the taxpayer can demonstrate that the inaccuracy was unintentional and reasonable care was taken. Additionally, HMRC will not impose penalties if a valid reason exists for failing to report property income correctly.

Where it can be demonstrated that there was a ‘reasonable excuse’ for the failure to report the previously undisclosed income and gains no penalty will be chargeable.

Over 100 countries, including the UK, have adopted the Common Reporting Standard (CRS), enabling automatic information sharing of potential tax relevance.

Additionally, HMRC's internal AI system, 'Connect,' extracts data from various sources to identify potential risks. This data-driven approach allows HMRC to easily identify individuals who may have received undeclared overseas income or gains.

Upon receiving such information, HMRC typically issues 'nudge' letters to encourage voluntary disclosure under the Worldwide Disclosure Facility.

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