A company can look substantial in a brochure, press release or website while its filings tell a much thinner story. The reverse can also happen: abbreviated or delayed filings may understate a genuinely active operation. An investigation should therefore treat a mismatch as a lead to test, not as proof of deception.
Define the claim before testing it
“Substance” is not one universal legal test. A claim may concern tax residence, regulatory presence, staffing, premises, decision-making or day-to-day operations. Record the exact wording, source and date of each claim, then identify the jurisdiction and reporting period it relates to. A statement that was accurate in March may not match accounts covering the previous December.
Start with a claim-and-evidence table. Put every public assertion in one column and the records capable of confirming or contradicting it in another. This keeps the review disciplined and stops a memorable anomaly from becoming the conclusion.
Compare several independent records
Corporate registers establish legal facts such as incorporation, officers, registered addresses and filing dates. Accounts may show revenue, assets, liabilities and staff costs. They should be read alongside licence registers, VAT records, insolvency notices, procurement records and, where lawfully available, payroll, leases, utility bills, contracts, invoices and payment activity.
A registered office is a statutory contact point, not automatic evidence of an operating headquarters. Likewise, an industry classification code is self-reported and does not prove that the declared activity is actually being conducted. Dormant status also has a specific accounting meaning and should not be inferred merely from a quiet website or a small balance sheet.
For UK companies, Companies House guidance on annual accounts explains what companies must keep and file, including records of money received and spent, assets and liabilities. Filing exemptions and reporting lags matter: smaller-company accounts may provide less detail, and the latest filing can describe a period that ended many months ago.
Test where decisions and work really occur
Board minutes, delegated authorities, executive correspondence and contract approvals can help establish who made important decisions and where. Travel records, meeting calendars and electronic-signature logs may corroborate that picture when obtained lawfully. Do not assume that a director’s home address, a company’s incorporation country or the location of a formal board meeting settles the issue.
HMRC’s company-residence guidance describes central management and control as a question of fact focused on the highest level of control. That is distinct from the location of routine operations. This is why investigators should examine management location as well as legal ownership.
Operational substance is tested differently. Look for employees or genuine contractors with relevant roles, suitable premises, equipment, customer support, supplier relationships and activity consistent with the stated business. VAT registration can add another useful timeline, but it is not conclusive by itself; our guide to using VAT data to uncover activity explains the necessary cross-checks.
Investigate contradictions without overstating them
Useful discrepancies include a claimed headquarters with no credible local presence, turnover without an evident operating path, regulated services provided by an entity absent from the relevant register, or public claims that conflict with dated accounts. A Malta Media investigation into Finrax’s corporate and financial footprint illustrates how reported revenue, employment and control across several jurisdictions can be compared. It is a secondary-source example, not a substitute for obtaining and checking the underlying records.
There may be ordinary explanations. Staff can be employed by another group company; revenue may be booked elsewhere under a disclosed arrangement; premises may have changed after the filing period; or a service company may legitimately supply the operating entity. Ask the company precise questions and preserve its response. Where possible, confirm the explanation through contracts, consolidated accounts, related-party notes or regulator records.
Write a defensible finding
Separate verified fact, reasonable inference and unresolved question. Cite the document, filing date and reporting period behind every important statement. Grade each discrepancy by reliability and significance, and state what evidence would resolve it. Before publication, give affected parties a fair opportunity to respond and include material answers.
The strongest conclusion is often narrower than the initial suspicion: the public claim is unsupported by the records reviewed, the records are incomplete, or the evidence points to operations being conducted elsewhere. That precision makes the investigation more useful—and far more defensible—than treating every mismatch as fraud.