Yes.
But as ever, it will depend upon the facts/evidence.
This applies whether you are a company or an individual.
Why would HMRC want to do that?
I can only comment from what I have seen to date and as ever, it will depend upon all the relevant facts. I would suggest that HMRC would not start proceedings unless it was as a last resort and all other avenues have been exhausted.
And any tax investigation/dispute/challenge is exhausting. The time spent looking up facts and figures (often more than once), the financial cost of paying professional charges. And don’t forget, there may also be tax due, with interest and often a penalty.
When will it all end? How will it all end?
By bankruptcy in some cases.
How can this be avoided?
Don’t ignore HMRC. They will not just give up and go away. They have a job to do, too.
If you have a letter from HMRC, open it and read it. Don’t ignore it, answer it. If for whatever reason you can’t answer it, seek help. Don’t ignore HMRC. Sometimes all that is needed initially is an acknowledgement that the letter has been received. Better still will be to include the fact that you will endeavour to respond by a specific date. Make a diary note to do so. Seek help. Preferably from a specialist with experience of answering such matters.
The response may be promised within 30 days, which is the “normal” turnaround time for HMRC. But you may already know that it will take longer in which case say so, give a longer date and give a reason for why it will take longer. It may be that in 30 days you will have a personal matter (a holiday etc,) which HMRC should accept without question if it’s the first exchange. But to use the same reason for say 10 successive times will be met with a strong retort from HMRC.
Can HMRC force me to respond?
Yes, sort of. But there are safeguards.
There is legislation such as Schedule 36 Finance Act 2008 that HMRC can use to penalise a lack of response that will automatically escalate over time. But HMRC can only ask for something that is reasonably required (to determine a tax liability) and having granted 30 calendar days to do so.
Can a taxpayer refuse to comply?
Yes. But then you will be asked for your reasons and if HMRC believes those reasons to be invalid, you may be invited to appear personally before a Tax Tribunal, akin to a court.
Is that what you really want?
Are you looking for a resolution?
If you want to have your day in court, maybe I am not the adviser for you. But if you are looking for help and options, let’s start talking.
I don’t have a magic wand. I don’t work for HMRC.
But my aim is to seek a resolution for you and allow you to move on. HMRC is not always right, but they need to be included in any dialogue not excluded and ignored.
How can matters escalate and over what period of time?
By way of a recent example, a man and wife owned their own limited company. Back in 2012, the company was highly profitable and one particular order produced an extra £500,000 of profit. They were sold a tax avoidance scheme “guaranteed to work” by the scheme provider (just before they themselves disappeared).
HMRC opened an enquiry into the company and the man and wife and asked for information and documentation. Initially this was provided but for various reasons it took 13 months from the date of HMRC’s letter.
HMRC asked more questions but they too went unanswered.
HMRC issued tax assessments. These were ignored and went unpaid but after 6 months, HMRC took the taxpayers to Court for unpaid tax and NIC.
Eventually the Court hearings were adjourned.
As we all know, HMRC have never liked tax avoidance schemes and the media has covered the Loan Charge, the Loan Charge Review etc. and everything was put on the back burner so to speak. But not forgotten.
Now, in 2026, HMRC are active after all these years. HMRC writes to each taxpayer and advises them that based on the information they hold that the scheme falls outside of the Loan Charge Review. Closure Notices are issued on all the years under investigation.
May 2026, bankruptcy proceedings are underway against all parties.
Putting all the possible legalities and niceties aside, the whole matter is typical of how not to deal with such a tax matter and demonstrates that after approximately 14 years it can lead to notification of the commencement of bankruptcy proceedings.
What can be done?
Seek advice early on from a specialist. A tax specialist. I was able to intercede before bankruptcy proceedings had commenced. Any later and it would have been down to an insolvency specialist, not me.
In summary
Ignoring anyone is not only impolite it is wrong. Even worse if it is HMRC being ignored.
On this occasion I could help. But I am hindered by the passage of time as information and documentation may no longer be available.
Don’t leave it too late.
Anyone seeking help can call me on 07979 313 010 or email me at paul@pmc.tax.