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A look into HMRC’s toolbox during a criminal investigation

Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.

HMRC have an array of far-reaching powers at its disposal which it can utilise when conducting criminal investigations. These powers include applying for and executing search warrants arrest of individuals obtaining documents and information through production orders disclosure notices/orders or even as a consequence of covert surveillance. This article explores these powers what they enable HMRC to obtain during a criminal investigation and the important practical steps and considerations to bear in mind when responding to such an investigation.

Search warrants

When HMRC suspect tax fraud it may apply for and then execute a search warrant pursuant to the Police and Criminal Evidence Act 1984 s 8 (‘PACE 1984’). The execution of such warrants are often referred to as ‘dawn raids’ as they are usually...

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