HM Revenue & Customs (HMRC) is better equipped and more determined than ever to address tax avoidance and evasion. In this episode, we explore what companies need to know when an enquiry notice arrives and how to respond transparently and promptly, without letting things spiral out of control.

Ashurst’s Neil Donovan and Sophie Suri are back for the first Corporate Crime & Investigations episode of 2026. This time, they are taking a look at HMRC's enquiry process and how this can lead to a period of investigation and external scrutiny for corporates. They also discuss the heightened detection risk from HMRC’s new whistleblower reward scheme.

Neil warns: "There's a risk this could very quickly spiral into a multi-agency investigation where you're fighting on various fronts and facing a whole spectrum in terms of liability risk." Sophie discusses how to respond to an enquiry notice. Among her practical suggestions, she emphasies the importance of taking advice early, understanding the limits on HMRC's powers, and strong record-keeping so that document requests can be handled efficiently.

To listen to this and subscribe to future episodes in the Corporate Crime & Investigatons mini-series, search for “Ashurst Legal Outlook” on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at ashurst.com/podcasts. And you can read about the 2026 global enforcement issues to watch out for in this Ashurst article.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.