If HMRC is pursuing a civil investigation, then there will probably be a penaltyto pay, as well as the tax and interest, if you have committed a fraud. We have helped many clients argue for the lowest possible penalty that their circumstances will allow.
Often in the cases we deal with that have some element of tax fraud, there may be other ‘non-deliberate’ errors. Making sure that deliberate and non-deliberate issues are properly identified will minimise any penalties that need to be paid.