HomeGuidesHMRC Investigation GuideQuestions Answered
📅 Updated March 2026 — 2025/26 tax year UK Limited Companies & Contractors

HMRC investigation — questions answered

What this page covers

Direct answers to the most common questions contractors ask about HMRC investigations — what triggers an enquiry, what HMRC can ask for, time limits, penalties, the IR35 worst-case scenario, and exactly how to protect yourself.

What happens if HMRC investigates my limited company?

Direct Answer

HMRC issues a formal notice and can request records going back up to 6 years (20 years if fraud suspected). Most enquiries resolve in 3–18 months. The vast majority of contractor enquiries close with little or no additional tax due — provided you have clean records and a qualified accountant representing you.

What are the three types of HMRC enquiry?

~80% of cases

Aspect enquiry

HMRC questions one specific aspect — a single expense, dividend timing, or deduction. Usually resolved quickly with documentation. 3–6 months.

Full enquiry

Every income source, expense, and deduction examined. Triggered by significant inconsistencies or random selection. 6–24 months.

Highest stakes

IR35 investigation

Specific challenge to your IR35 status. Multiple years simultaneously. Potential for very large backdated liabilities. 12–36 months.

What triggers an HMRC investigation?

HMRC uses CONNECT — a data-matching system cross-referencing banks, Companies House, Land Registry, DVLA, and overseas tax authorities — to risk-score every tax return.

Large or unusual expense claims relative to turnover

Consistent losses year after year

Variance from industry benchmarks for your sector

Long-term single-client relationship (IR35 risk indicator)

Moving from permanent employment to contracting with the same employer

A tip-off from a client, recruiter, or former employer

Random selection — HMRC selects a proportion of returns every year regardless

What records can HMRC ask for?

Business bank statements — all accounts

Sales invoices and purchase receipts

Payroll records and RTI submissions

VAT records and returns

Dividend minutes and vouchers

Client contracts and Status Determination Statements

Mileage logs and travel records

Accounting software data

You cannot refuse a formal information notice. Failure to respond carries penalties. Having organised digital records speeds up the process significantly.

How far back can HMRC investigate?

SituationHMRC time limit
Standard — reasonable care taken12 months from filing deadline
Careless error4 years from end of relevant tax year
Deliberate error6 years from end of relevant tax year
Fraud20 years

What are the penalties if HMRC finds an underpayment?

BehaviourPenalty range
Reasonable care taken — honest errorNo penalty (tax + interest only)
Careless error0–30% of unpaid tax
Deliberate error (not concealed)20–70% of unpaid tax
Deliberate and concealed30–100% of unpaid tax

Interest accrues at approximately 7.75% per annum on unpaid tax. Penalties are reduced for voluntary disclosure and cooperation with HMRC.

What is the IR35 worst-case scenario?

Example: 3 years of IR35 non-compliance at £80,000/year

Additional Income Tax and NI (3 years): ~£50,000–£65,000

Interest on late payment: ~£5,000–£10,000

Penalties (careless): £0–£20,000

Professional accountancy fees: £5,000–£15,000

Total exposure: £60,000–£110,000+

This is why maintaining a strong IR35 position with proper contracts, an SDS, and specialist accountancy is not optional — it is the single most important financial protection a contractor has.

What is the enquiry process step by step?

1

Opening letter — formal notice from HMRC stating the enquiry is open and what they want to examine. You cannot refuse.

2

Information request — HMRC asks for specific records. Typically 30 days to respond. Your accountant prepares and submits everything.

3

Review and correspondence — HMRC reviews records and asks follow-up questions. This phase can take months. Your accountant manages all communication.

4

Resolution — written closure notice confirming no additional tax, or stating the agreed amount. Most cases settle here.

5

Tribunal (if disputed) — you can appeal to the First-tier Tax Tribunal. Most enquiries settle before this stage.

How do I protect myself?

Keep complete digital records in accounting software — bank statements, receipts, invoices, mileage logs

File all returns accurately and on time

Maintain a strong IR35 position — proper contracts, SDS, evidence of working practices

Keep dividend minutes and vouchers for every dividend payment

Use a specialist contractor accountant who reviews your position proactively

Have fee protection insurance — covers professional costs if HMRC opens an enquiry. Autobooks includes this as standard for all clients.

What is fee protection insurance?

Fee protection insurance covers your accountant's professional fees during an HMRC enquiry. Accountants charge £150–£300/hour for enquiry work — a full investigation can cost thousands in professional fees alone, even if no additional tax is found. Fee protection insurance means you don't pay those costs. Autobooks includes fee protection insurance as standard for all clients — so if HMRC comes knocking, your defence costs are covered.

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An IR35 investigation is the worst-case scenario for any contractor. Use our free 15-point checklist to assess your contract before HMRC does.

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IR35 Contract Checklist
15 questions · 2025/26

Fee protection insurance covers your defence costs if HMRC investigates.

Autobooks includes fee protection insurance as standard for all clients — from £89+VAT/month.