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HMRC Dawn Raids under PACE 1984: Practical Client Response Checklist (England and Wales)

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During a criminal inquiry, HMRC may apply to a magistrate for a warrant authorising entry to and search of premises. It may also seize and retain any material specified in the warrant. The extent of HMRC’s powers to investigate criminal offences, and the situations in which they may be exercised, is outlined in Practice Note: HMRC criminal investigations and dawn raids.

This Checklist offers a practical set of dos and don’ts for a dawn raid. It can act as a handy reference for clients who might face a dawn raid. The procedures described should be communicated to staff in advance. As the client will not know about the raid before it happens, this may be problematic. It may be possible to circulate the guide on a ‘just in case’ basis. It is also sensible to train key staff on how to manage and respond to a dawn raid.

What to expect in a dawn raid

In a tax context, a dawn raid means a visit from HMRC under the authority of a search warrant (issued under section 8 of the Police and Criminal Evidence Act 1984). A dawn raid will...

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Web page updated on 22/05/2026

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