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With HMRC becoming increasingly more active, and tax legislation becoming ever more complicated, it is now even more important than ever, to resolve disputes with HMRC as quickly and as cost-effectively as possible or, prevent them arising in the first place.
Our Tax Risk and Dispute Resolution team have a wealth of experience in dealing with HMRC – understanding their approach to risk, enquiry processes and decision-making governance.
We offer:
Proactive Tax Risk management
HMRC’s view in relation to a potential problem, should not only be considered when a filing deadline is approaching. Proactively anticipating when transactions and events increase tax risk enables you to make an informed decision as to whether to act now to reduce the risk of a tax enquiry further down the line.
For many corporates and individuals, it is possible to identify high value or complex transactions that will change their footprint with HMRC when the next return is filed. Enquiries and disputes can often be prevented by:
- Understanding inherent and specific tax risk during the year;
- Revising transactions if a less risky tax route is possible;
- Collating appropriate advice and evidence in real time whilst key people are available; and
- Potentially engaging with HMRC pre-filing to reduce the risk of a later dispute arising.
Strategic discussion about tax risk and deciding whether or not to take action to mitigate areas of risk can remove a layer of uncertainty, provide clarity, and minimise the chance of an enquiry.
Examples of tax events where the risk can be proactively managed include:
- Arriving into or leaving the UK.
- Restructuring trust and offshore arrangements.
- Reworking trust pools pre-distribution if there are historic issues.
- Crystalisation of wealth (i.e. the sale of a business).
- Business Investment Relief.
- Funding of lifestyle for non-domiciled individuals.
- Complex technical situations.
- Medium-sized businesses who do not have an Senior Accounting Officer obligation but would like a level of tax risk management for governance.
- Building relationships with HMRC so that tax returns are viewed and understood in the right context.
Tax Dispute Resolution
HMRC investigations are generally time consuming and stressful experiences. Our experienced team can help to minimise the stress and disruption of an investigation, guiding you along the path to a resolution that is appropriate and justified.
For individuals, trusts, and corporates, we can assist with:
- Individual and corporate aspect enquiries.
- Cross-tax company enquiries.
- Serious investigations such as CoP9 (Civil Investigation of Fraud) or CoP8.
- Disclosures, particularly offshore or cross-jurisdictional.
- Approaching HMRC to settle legacy avoidance schemes such as EBTs, Contractor Loan schemes etc.
- Dealing with Accelerated Payment Notices or Follower Notices.
- Alternative Dispute Resolution (mediation).
- Complex technical disputes with HMRC heading towards litigation at Tax Tribunal.
- Cross-jurisdictional disputes where different territories are both asserting taxation rights.
- Disputes involving penalties and time limits.
- Dealing with HMRC formal information notices, third party information notices, production orders or raids.
- Negotiating time to pay arrangements.
Contact our specialist team
Contact our specialist team
- Jessica McLellan – Tax Risk & Dispute Resolution Partner
- +44 (0)20 7832 0444