HMRC Enquiry meetings: What customers/clients/taxpayers need to know

Overview
An HMRC enquiry meeting forms a pivotal part of a wider investigation into personal or business tax affairs—whether you’re a sole trader, partner, or corporate entity. These meetings allow HMRC to test the credibility of records, clarify disclosures, and observe behavioural indicators that may influence outcomes—ranging from routine adjustments to significant penalties.

These meetings may arise in the context of income tax, corporation tax, VAT, PAYE, R&D relief, or other obligations. Critically, once a meeting is proposed—by HMRC, yourself, or your adviser—you should already know whether it’s a full or aspect enquiry under civil powers, or a Code of Practice 9 matter involving suspected tax avoidance or fraud.

When and why, they occur

Enquiry meetings typically follow formal HMRC action under:

• Section 9A (individual self-assessment)
• Schedule 18 FA 1998 (corporation tax)

In general HMRC uses these meetings to:

• Assess the credibility of records and representations
• Clarify anomalies or omissions
• Gauge behavioural indicators (negligence vs. intent)
• Define the scope and direction of the enquiry
• Encourage voluntary disclosure where liabilities appear understated

What to expect: key meeting components

1. Notice and framing - You will receive a formal invitation, which should provide details of what to expect, sometimes a list of the initial questions. It may be accompanied by a Schedule 36 Notice or reference to enquiry powers
2. Attendees - HMRC officers (compliance, specialist or investigative teams), the taxpayer or director, and their professional adviser. 
3. Venue - Prior to COVID these could be at HMRC premises, taxpayer offices/business. Now almost exclusively they are virtual meetings. VAT meetings remain the exception.
4. Meeting format - HMRC outlines your rights, potential penalties, and whether the meeting is civil or COP9 (potential fraud). If they suspect inaccuracies, they must inform you of your rights at that point. If it’s a criminal investigation you will know, because you will be, or have been, interviewed at a Police station. 
5. Discussion topics - Technical issues (e.g., relief eligibility, undeclared income, classification)
• Factual matters (timing of transactions, contractual details)
• Process and compliance (record-keeping, governance, agent conduct)
• Any errors or omissions identified
6. Tone - Meetings can be either collaborative or adversarial. Professional rigour and/or close questioning is not hostility—it’s an HMRC officer doing their job well. A good agent will prepare you for that. However, in the main the majority of HMRC enquiry meetings are cordial. The attitude and behaviour of all parties present plays a critical role in outcome.
7. Duration - Typically, 1–2 hours (rarely beyond 3 hours to avoid fatigue). A skilled officer defers technical tax / accounting queries to a follow-up with your adviser to keep taxpayer time focused.
8. Post-Meeting Actions - Request HMRC’s meeting notes. Expect further document requests, formal notices, or settlement offers. 

Top tip: Agents / accountants or you should always make contemporaneous handwritten notes of the key points and exchanges that occure during meetings with HMRC. Do not record meetings without HMRC’s express consent. Unauthorised recordings can damage trust and may not be accepted by a tribunal, depending on how they were obtained and their relevance. Any concerns that  without recordings, HMRC officers will deny or change what was said are all easily dismantled by a  skilled tax enquiry professional — and tribunals give it little weight to such ploys.

(Feel free to ask in the comments why HMRC refuses to allow these meetings to be recorded — I’m happy to explain.)

Key risks and consequences arising from HMRC meetings

• Penalty Positioning: Admissions can affect the classification of errors (e.g., careless vs. deliberate)
• Extended Enquiries: Lack of clarity or poor preparation can lengthen the process
• Assumptions: Gaps in explanation may lead to adverse inferences
• Escalation Risk: If fraud indicators are present, HMRC may shift to criminal pathways

Preparing for an enquiry meeting

1. Clarify the enquiry scope - Precisely.

1. Appoint a specialist adviser - NEVER go alone, even with prior advice. Remember anything that starts informal with HMRC, ALWAYS has formal consequences.
2. Compile organised evidence - contracts, bank statements, correspondence.
3. Review your filings - to speak confidently to them.
4. Rehearse the meeting and key responses - A good adviser will run through the key points with you before the meeting. A great one will show you how to stay clear, factual, and neutral — and, assuming you’ve acted compliantly, equip you with everything you need to handle any question with calm confidence.
5. Know your rights - You are not obliged to answer every question immediately. Clarify or defer as needed – your advisor should step in here. An good experienced HMRC officer will not expect you to remember every minutia of events and transactions.
6. Manage the meeting calmly - Stick to facts. Avoid speculation or over-explaining. Let your adviser lead if challenged.
7. Follow-up diligently - Compare meeting notes, clarify inaccuracies. any additional supporting or clarifying information where you need to. Submit requested material.

Strategic significance

Enquiry meetings aren’t just procedural—they are transformative. With meticulous preparation, they offer an opportunity to:

• Clarify misunderstanding
• Illustrate transparency
• Steer the enquiry toward swift and positive conclusion

When handled with professionalism and clarity by all parties I have seen HMRC officers close an enquiry after a single hour at a meeting—without amendment.

Final thought

HMRC enquiry meetings are live tests of planning, conduct, and response.
Preparation, calm authority, and strategic insight separates success from the rest.

Thank you for reading this.