Our team can assist you in providing advice, strategy and solutions for high value, complex tax enquiries into individuals, owner managed businesses, partnerships and corporates. The typical cases we advise on are:

• Complex enquiries carried out by local HMRC offices, including corporate “cross-tax” enquiries (income tax, PAYE, VAT, inheritance tax and capital gains tax)
• Suspected fraud enquiries carried out by HMRC’s Fraud Investigation Service under Code of Practice 9 (working together with our Financial Crime team, where appropriate)
• Enquiries carried out by HMRC under Code of Practice 8. These are typically complex technical civil enquiries where Code of Practice 9 is not deemed suitable
• Employer compliance (PAYE) reviews undertaken by HMRC’s employer compliance team

The team can also review a client’s current and historic participation in marketed tax avoidance schemes. We advise on the options available using our up to date and detailed knowledge of HMRC Counter Avoidance Directorate policies.

We also advise on other tax avoidance issues including:

• Accelerated Payment Notices
• Follower Notices
• The Serial Tax Avoiders Regime
• Disguised remuneration paid via employee benefit trusts (EBTs) and contractor loan schemes
• The 2019 “loan charge”
• Settlement with HMRC including deferred payment arrangements

The team also assists with other HMRC related issues including:

• Providing advice and assistance with overpayment relief claims
• Facilitating and voluntary disclosures to HMRC where UK and/or offshore income, profits or gains have been overlooked
• Challenging the legitimacy of HMRC discovery assessments, penalties, information and document requests and other inappropriate HMRC decisions, where necessary working with our Tax Litigation team