Resolution of Tax Disputes with HM Revenue & Customs are a fact of life in the modern world as the Government strives to increase the tax base and in particular, the yield from existing taxpayers.
We can deal with a wide range of tax disputes with HMRC but where we need specialist advice, particularly in the area of resolving tax avoidance issues we work with a strategic partner..
Our partner has a track record of successfully resolving all kinds of direct taxation disputes, usually by negotiation but also through strategic litigation. They will robustly defend their clients’ legitimate technical positions through “Internal Review” and at the Tax Tribunal when appropriate, usually working with the client’s existing accountants and other professsional advisers.
Recent cases handled include:
- Code of Practice 9 (Serious tax fraud)
- Code of Practice 8 (Cases involving tax avoidance)
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Disclosures to HMRC under the Liechtenstein Disclosure Facility and other HMRC disclosure opportunities
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Technical tax disputes with Local Compliance Centres and specialist HMRC departments
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Aspect and full enquiry cases for companies individuals and trusts
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Residence and domicile disputes
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Issues surrounding offshore structures
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“Failure to notify” (undisclosed income sources)
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PAYE, CIS, IR35 and other employment related tax disputes
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Tax debt management issues
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Penalty negotiations and appeals
They have significant recent experience of all of the following:
- Statutory Internal Review
- Tax tribunal cases
- Appeals to higher courts
- Judicial Review proceedings
- Mediation in civil tax disputes
For further information please contact us