On the flipside, this means taxpayers in some smaller cases, after they have been notified by HMRC, can ask to investigate their own tax affairs with their own advisers and then report back.
"That's obviously much less intrusive than the revenue doing it. And gives you the opportunity to sort of review the situation in a bit of safe space and then report back to them what you found," says Porter.
He adds: "Those are the best outcomes you get from investigations where you engage early, get the safe space, get to do the investigation in the background and then report back to HMRC what you find.
"Those have the best outcomes overall because you've shown positive engagement with HMRC and that's looked on favourably for penalties as well. The only downside to that is it obviously costs you more in fees."
carmen.reichman@ft.com
