New corporate criminal offence: what will an investigation look like?

HMRC has stepped up its criminal investigations into corporates, without waiting for the new corporate offence to become effective (expected to be September 2017). The new offence will make it much easier to prosecute. Don’t expect HMRC to wait too long for the new offence to bed in before the department starts to investigate. Also, don’t think this offence is just for banks and professional advisers. It only takes one person acting wrongly for an organisation to be under investigation. Large companies should therefore refresh their raids and critical incident procedures, in particular to make sure the right escalation procedures are in place if HMRC officers appear without warning.