Coming under enquiry by HMRC can be a daunting and stressful experience. Our Specialist Tax Dispute Resolution team is experienced in addressing HMRC’s concerns and bringing matters to a fair conclusion whilst keeping your direct involvement to a minimum so you can concentrate on the more pleasant things in life.
We manage all stages of the process with HMRC from meeting with HMRC to understand their concerns and agree the work required through to gathering the information necessary to establish the relevant facts and presenting those facts to HMRC, quantifying the amount of any additional tax payable, negotiating with HMRC where the facts are unclear or the technical position is open to alternative interpretation and ultimately concluding a final settlement with HMRC to draw a line under the past and bring all of your tax affairs to up to date.
We liaise and work closely with all of your existing advisors – including your lawyers, the accountants handling your routine affairs, your investment managers and any professional trustees or executors.
The areas we specialise in include:
- serious civil investigations of suspected fraud conducted by HMRC Fraud Investigation Service (“FIS”) under Code of Practice 9 (“COP 9”) / the Contractual Disclosure Facility (“CDF”)
- major investigations conducted by HMRC under Code of Practice 8 (“COP 8”) where fraud is not suspected but matters are complex and the potential outstanding tax is large
- broad ranging enquiries into individuals, their business interests and family trusts
- making voluntary disclosures to HMRC where omissions or possible omissions need to be brought to HMRC’s attention – for instance:
- disclosures of overseas related matters under the Worldwide Disclosure Facility (“WDF”)
- disclosures of omitted income from letting residential properties under the Let Property Campaign
- general disclosure through HMRC’s Digital Disclosure Service
- disclosures of complex matters to HMRC specialist technical teams
- resolving the tax consequences arising from non-tax disputes and Court imposed remedies – for instance, commercial disputes and family disputes over assets
- exiting and settling matters related to marketed tax avoidance arrangements
- advice on how to respond to HMRC “nudge letters” hinting – maybe wrongly - that you might have something to tell them about
- Instruction of Tax Counsel, bringing appeals to the Tax Tribunal, appeal management and case support
- Resolving HMRC investigations and making voluntary disclosures to HMRC with regard to furlough claims made under the Coronavirus Job Retention Scheme
For further information or for a free consultation please use the contact form below.