A number of our clients are the subject of direct and indirect tax investigations by HMRC into their personal, business and corporate affairs, which frequently include aspects such as offshore accounts and trusts.
These investigations range from enquiries into an individual’s tax return for one year to complex detailed reviews of financial affairs including UK and overseas entities stretching back several years.
Our role, in all investigation cases, is to establish the facts, determine the tax consequences of those facts and negotiate the best position for the client with HMRC. Having first-hand knowledge of the processes and procedures which HMRC operate under, enables us to have a unique viewpoint and as such we can advise clients on the complex tactics and strategies employed by HMRC from the very outset of a case.
Over the last 6 years we have dealt with hundreds of disclosure cases which have used the various disclosure facilities offered by HMRC and negotiated some interesting settlements for clients. Increasingly we are advising clients in situations where the Inspector and the client have reached an impasse in their discussions. We can provide alternative views and proposals to bring the dispute to a satisfactory resolution.
We also act in cases where HMRC have decided to prosecute instead of dealing with a case on a civil basis and again we work closely with the client and their legal advisors.