Should You Attend an HMRC Meeting Without Professional Representation?

Receiving an invitation to meet HMRC can feel unsettling.

For many taxpayers, the first question is:

“Do I really need an accountant or tax adviser with me?”

The answer depends on what HMRC wants to discuss.

A short meeting about a simple factual issue may not justify professional representation. However, a meeting about undeclared income, poor business records, overseas accounts or possible penalties requires much more care.

HMRC officers take notes during compliance meetings. Those notes can support later conclusions, assessments and penalties. Therefore, what you say may matter long after the meeting ends.

Professional representation cannot change the facts. However, it can help you understand HMRC’s questions, provide accurate answers and avoid creating confusion through guesswork or incomplete explanations.

Can You Attend an HMRC Meeting Without an Accountant?

Yes.

There is no general rule that requires a taxpayer to have an accountant, tax adviser or solicitor at every HMRC meeting.

You may choose to:

• attend by yourself;
• attend with an accountant or tax adviser;
• attend with a solicitor;
• ask an authorised adviser to speak to HMRC on your behalf; or
• ask a friend or relative to support you, subject to suitable authorisation.

HMRC’s current compliance-check guidance also says that you can choose whether to attend an ordinary meeting.

However, refusing a meeting does not end the compliance check.

HMRC may continue through written questions. It may also use formal information powers to obtain records or explanations that it reasonably requires.

Importantly, a voluntary meeting is different from a formal information notice or an inspection authorised under HMRC’s statutory powers. You cannot safely ignore a legal notice simply because you chose not to attend an earlier meeting.

Therefore, before deciding what to do, identify exactly what HMRC has requested.

Why Does HMRC Want a Meeting?

The purpose will depend on the tax and issues under review.

HMRC may want to:

• understand how a business operates;
• clarify figures on a tax return;
• discuss particular transactions;
• review the bookkeeping system;
• ask about undeclared or unexplained income;
• examine business or personal expenditure;
• understand property or overseas activities;
• establish how an error occurred;
• discuss missing records; or
• determine the correct amount of tax.

A meeting does not automatically mean HMRC believes that you committed fraud.

Sometimes, speaking to the taxpayer helps the officer understand records that look unclear on paper. A clear explanation may even help resolve the check more quickly.

Nevertheless, you should not treat the meeting as a casual conversation.

HMRC may ask questions designed to establish not only what went wrong but also why it went wrong. The answer can affect the number of years HMRC reviews and the level of any penalty.

Why Can Attending Alone Be Risky?

The main risk is not necessarily that HMRC will try to trick you.

Instead, you may not recognise why a question matters.

For example, HMRC might ask:

“Why did you leave this income off your return?”

You might answer:

“I forgot about it.”

That may be an honest answer. However, HMRC may then ask what records you kept, whether you checked them and what steps you took to ensure the return was accurate.

Those details may affect whether HMRC views the error as:

• despite taking reasonable care;
• careless;
• deliberate; or
• deliberate and concealed.

Similarly, an apparently simple question about a business expense may lead to wider questions about the accounting records, private use or the accuracy of several tax returns.

Other common risks include:

• answering from memory when records would give a better answer;
• agreeing with an assumption before checking it;
• describing an estimate as an exact figure;
• volunteering unrelated information without context;
• misunderstanding technical tax language;
• giving an answer that conflicts with an earlier document; or
• failing to mention evidence that supports your position.

Professional representation does not allow anyone to avoid a proper answer. However, it can help ensure that the answer remains accurate, relevant and complete.

What Can an Accountant or Tax Adviser Do?

A professional adviser can provide more than moral support.

Before the meeting, they may:

• review HMRC’s letter;
• identify the tax years and issues involved;
• examine the relevant returns and calculations;
• compare HMRC’s concerns with the available evidence;
• identify areas that require further work;
• explain the possible tax and penalty risks;
• help prepare a clear timeline; and
• discuss likely questions with you.

During the meeting, the adviser may:

• ask HMRC to clarify an unclear question;
• explain technical tax treatment;
• correct a misunderstanding;
• make sure relevant evidence receives proper attention;
• distinguish confirmed facts from estimates;
• help keep the discussion within its stated scope; and
• take their own detailed notes.

After the meeting, they can:

• review HMRC’s meeting notes;
• correct factual inaccuracies;
• supply further documents;
• answer follow-up questions;
• review any proposed tax calculation; and
• challenge conclusions where appropriate.

However, the taxpayer remains responsible for providing accurate information.

An adviser can only represent your position properly if you give them all the relevant facts—including the uncomfortable ones.

Does HMRC Record What You Say?

HMRC officers must take notes during arranged compliance meetings.

HMRC’s internal guidance says officers should make notes during or immediately after the meeting. It also requires HMRC to retain those notes with the compliance-check records.

In some direct-tax cases, HMRC will send typed meeting notes to the taxpayer or their agent. HMRC may ask the taxpayer to agree and sign them.

Do not sign meeting notes without reading them carefully.

Check whether the notes:

• reflect what you actually said;
• separate facts from assumptions;
• include any important qualifications;
• describe estimates accurately;
• record documents that you agreed to provide; and
• correctly state any point that remained unresolved.

If the notes contain errors, respond in writing. Set out the correction clearly and keep a copy.

You may also prepare your own note immediately after the meeting, while the discussion remains fresh in your mind.

What If You Do Not Know the Answer?

Do not guess.

It is reasonable to say:

“I do not know the answer without checking the records. I will review them and respond in writing.”

This is usually safer than giving an immediate answer that later proves incorrect.

You can also ask HMRC to:

• repeat or rephrase a question;
• explain why the information matters;
• identify the tax year involved;
• allow time to check the records; or
• confirm the question in writing.

However, do not use “I do not know” to avoid answering every question. HMRC may expect you to make reasonable efforts to establish the facts.

A useful distinction is:

Type of information	Appropriate approach
A fact you know clearly	Answer accurately and directly
A fact shown by the records	Check the document before answering
Something you only partly remember	Explain the uncertainty
A technical tax question	Ask your adviser to explain or respond later
A figure that requires calculation	Do not estimate unless you label it clearly
Information you do not hold	Explain why and identify possible alternatives

Accuracy matters more than speed.

When May Attending Alone Be Reasonable?

Attending without professional representation may be reasonable where:

• HMRC wants to clarify a simple factual point;
• only one straightforward transaction is involved;
• the possible tax exposure is small;
• you fully understand the tax treatment;
• you have complete supporting records;
• HMRC has not identified serious inaccuracies;
• penalties are unlikely to become a significant issue; and
• you feel confident explaining the position clearly.

For example, HMRC may need to confirm the date on which a business stopped trading or clarify why two documents show different reference numbers.

Even in a straightforward case, read the HMRC letter carefully and prepare before attending.

When Should You Seriously Consider Representation?

Professional representation becomes more valuable where the meeting involves:

• several tax years;
• undeclared income;
• substantial tax liabilities;
• missing or unreliable records;
• overseas income, assets or accounts;
• large cash transactions;
• director’s loan accounts;
• complex business arrangements;
• disputed private and business expenditure;
• potential discovery assessments;
• possible penalties;
• questions about careless or deliberate behaviour;
• COP8 or COP9; or
• the possibility of criminal investigation.

You should also consider representation where you feel too anxious or overwhelmed to deal with the meeting clearly.

The decision should remain proportionate. However, saving professional fees at the start may prove expensive if unclear answers lead to wider questions or incorrect conclusions.

What If HMRC Mentions Deliberate Behaviour?

Take particular care.

Deliberate behaviour means more than making an ordinary mistake. HMRC may consider whether the taxpayer knowingly submitted an incorrect return or deliberately withheld information.

A finding of deliberate behaviour can affect:

• the penalty range;
• how far back HMRC can assess;
• whether HMRC publishes the taxpayer’s details;
• whether HMRC places the taxpayer under enhanced monitoring; and
• in serious cases, whether HMRC considers criminal investigation.

HMRC’s own internal guidance says that if an unrepresented taxpayer’s meeting reveals potentially significant and culpable errors, the officer should give them an opportunity to obtain professional help.

If HMRC suggests deliberate conduct, ask for time to take specialist advice before answering detailed questions about behaviour.

This does not mean refusing to cooperate. It means making sure you understand your rights and the consequences before providing substantive answers.

What If the Letter Refers to COP8 or COP9?

COP8 and COP9 are specialist HMRC investigation procedures.

COP8 normally concerns suspected tax avoidance or other complex arrangements where HMRC does not initially suspect deliberate tax fraud.

COP9 applies where HMRC suspects serious tax fraud and offers the taxpayer the Contractual Disclosure Facility.

These cases require specialist advice.

Do not treat a COP8 or COP9 meeting as an ordinary compliance discussion. Review the correspondence with an adviser experienced in tax investigations before responding or attending.

Our guide to COP8 and COP9 investigations explains the key differences.

Can Your Adviser Attend Instead of You?

Sometimes.

An authorised adviser can handle much of the correspondence and may attend meetings on your behalf.

However, HMRC may still want to speak directly to you about:

• how the business operated;
• what you knew at a particular time;
• why you took a particular action;
• personal financial matters; or
• events that only you can explain.

HMRC requires formal or temporary authorisation before it can discuss confidential tax information with an adviser.

Even where the adviser leads the meeting, the taxpayer should remain involved enough to check that the information supplied is accurate.

Meeting HMRC With or Without Representation

Attending alone	Attending with professional representation
You interpret HMRC’s questions yourself	The adviser can clarify the purpose of questions
You explain all technical matters	The adviser can explain complex tax treatment
You may rely too heavily on memory	The adviser can connect answers to records
You take your own notes	The adviser can keep a separate meeting record
Lower immediate professional cost	Professional fees apply
May suit a simple factual discussion	More useful for complex or higher-risk cases
You manage all follow-up work	The adviser can handle further correspondence
Greater risk of missing the significance of a question	The adviser can identify tax and penalty implications

Representation does not guarantee a better outcome.

Its value lies in preparation, clarity and reducing the risk of avoidable mistakes.

What If You Have Already Attended Alone?

It is not too late to seek advice.

Gather:

• the original HMRC letter;
• your own meeting notes;
• any notes HMRC sent to you;
• the documents you provided;
• follow-up questions;
• relevant tax returns; and
• any proposed tax or penalty calculations.

An adviser can then review whether anything needs clarification.

If an answer was incomplete or inaccurate, correct it promptly. Do not wait and hope that HMRC will overlook the issue.

A clear written correction supported by evidence may prevent a misunderstanding from becoming part of HMRC’s final conclusion.

What Happens After the Meeting?

The meeting will rarely end the process immediately.

HMRC may:

• ask further questions;
• request additional records;
• compare answers with other information;
• amend its understanding of the case;
• propose additional tax;
• consider interest and penalties;
• issue an assessment; or
• close the check without adjustment.

If HMRC asks for further information, check whether the request is relevant and reasonable.

An informal request differs from a formal Schedule 36 information notice. A formal notice can carry appeal rights, deadlines and penalties for failing to comply.

Our guide to HMRC information notices explains the general rules.

Practical Guide: Preparing for an HMRC Meeting

1. Read the HMRC letter carefully

Identify what HMRC is checking, the tax years involved and every deadline.

2. Ask for an agenda

Request a clear explanation of the subjects HMRC wants to discuss.

3. Review the relevant returns

Do not rely on memory. Read the returns, calculations and supporting notes.

4. Gather the evidence

This may include bank statements, invoices, accounts, contracts, property records and overseas documents.

5. Identify difficult areas

List missing records, unusual transactions and points that you cannot yet explain.

6. Prepare a timeline

A clear sequence of events can help where the case covers several years.

7. Decide whether you need representation

Consider the tax at risk, number of years, possible penalties and complexity.

8. Agree who will answer

If an adviser attends, decide which questions they will answer and which require your direct knowledge.

9. Do not guess

Ask to check the records and respond later where necessary.

10. Keep your own notes

Record the questions, answers, documents requested and deadlines agreed.

11. Review HMRC’s notes

Correct factual errors promptly and in writing.

12. Complete follow-up actions

Provide agreed information by the deadline or request more time before it expires.

Frequently Asked Questions

Do I have to attend an HMRC meeting?

HMRC’s general compliance guidance says you can choose whether to attend an ordinary meeting. However, refusing does not stop the check. Formal information notices and authorised inspections involve separate legal rules.

Will refusing a meeting make me look guilty?

Not automatically. You may prefer to respond in writing or through an adviser. However, a refusal without a practical alternative may make the check slower and could affect HMRC’s view of your cooperation.

Can HMRC interview me without my accountant?

You can choose to speak with HMRC alone. However, you have the right to appoint a representative. If the discussion identifies potentially serious errors, ask for time to obtain advice.

Can I ask HMRC to send its questions in writing?

Yes. HMRC may agree to written questions, particularly where you need to check detailed records. However, it may still consider a meeting the most effective way to understand the facts.

Should I answer every question immediately?

No. Answer what you know accurately. If you need to check a document or calculation, say so and agree to respond later.

Can HMRC use what I say to calculate penalties?

Yes. HMRC may use meeting answers when deciding what happened, why it happened and how much cooperation you provided. These matters can affect penalties.

Can my accountant speak for me?

Often, yes, provided HMRC has the correct authorisation. However, HMRC may still ask you to answer questions about matters within your personal knowledge.

Can I bring a solicitor instead of an accountant?

Yes. The most suitable representative depends on the issue. A solicitor may be particularly important where there is a possible criminal investigation or questions of legal privilege.

Should I sign HMRC’s meeting notes?

Read them carefully first. If anything is inaccurate or incomplete, set out your correction in writing rather than signing an incorrect account.

What if anxiety or poor health makes the meeting difficult?

Tell the HMRC officer. HMRC says it can provide extra support and reasonable adjustments for health and personal circumstances. You may also authorise someone to help you.

Where to Find Official HMRC Information

Current official guidance includes:

• HMRC compliance checks: help and support, explaining meetings, representation and taxpayer responsibilities.
• About compliance checks — CC/FS1a, covering the choice to attend a meeting, authorising a representative and HMRC’s legal powers.
• HMRC guidance on notes of meetings, explaining how officers create, retain and use meeting notes.
• HMRC guidance on preparing for business-enquiry meetings, including the opportunity for an unrepresented taxpayer to obtain advice where serious errors emerge.
• Authorise a tax agent, explaining how an adviser can deal with HMRC on your behalf.
• HMRC compliance-check factsheets, covering information notices, inspections, penalties and taxpayer rights.
• The HMRC Charter, setting out the standards taxpayers can expect from HMRC.

The correct approach depends on the type of meeting and the possible consequences. Therefore, seek specialist advice where HMRC raises deliberate behaviour, COP8, COP9 or possible criminal investigation.

💡 Key Takeaway

You can usually attend an HMRC meeting without professional representation. You may also choose not to attend an ordinary compliance meeting.

However, the real question is not simply whether you are allowed to attend alone.

It is whether you understand the issues, have the right records and can explain the position accurately without guessing.

For a straightforward factual discussion, attending alone may be reasonable. Where the meeting involves historic errors, undeclared income, overseas matters, significant liabilities or possible deliberate behaviour, professional representation can provide valuable clarity and protection.

The purpose is not to make the meeting confrontational. It is to ensure that HMRC receives an accurate and properly supported explanation.

Need Help?

If HMRC has invited you to a meeting, Accounts Tax Group can review the letter, explain what HMRC appears to be examining and help you decide whether representation is appropriate.

We can prepare you for likely questions, review the relevant tax returns and records, attend the meeting where necessary and handle follow-up correspondence.

Contact us before the meeting wherever possible. Good preparation is much easier than correcting an unclear or inaccurate answer afterwards.

For further practical guidance, explore our HMRC Insights and Updates.

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