To be or not to be…a body corporate
30 September 2021 marked the four-year anniversary since the implementation of the Corporate Criminal Offence legislation as per part 3 of the Criminal Finance Act 2017 (‘CFA 2017’).
Tax investigations can be extremely varied, complex and stressful. Therefore, it is imperative to have the support of advisers with an extensive and market-leading understanding of HMRC investigations, policies and procedures.
Our team advise clients who are subject to tax disputes but we can also work with clients to proactively managing their risk of such disputes via the implementation of tax strategies, policies and procedures.
Our approach
Our approach to resolving tax disputes is bespoke to each and every client. No two investigations are the same; therefore we take time to understand the client’s position before engaging with HMRC. We establish the facts, assess the situation and coordinate our resolution strategy in conjunction with the client. We actively engage with HMRC to understand the risks and concerns identified before seeking to bring the matter to settlement.
Our experience
Our Tax Dispute Resolution team has a broad range of specialists with many years of HMRC dispute resolution experience. Many of the team have previously held senior roles in HMRC, either as Group Leaders of HMRC’s Fraud Investigation Service (FIS) or HNWI teams, FIS Investigators, HMRC Policy Teams, HMRC’s Large Business Office and HMRC’s Solicitors Office.
The team is also at the forefront of Tax Governance, including the implementation of Corporate Criminal Offence (CCO) policies and Senior Accounting Officer (SAO) reviews.
We have a national coverage of specialists all over the country to assist you but also represent clients from all over the globe who are subject to HMRC investigation.
Get in touch
If you need support with a tax investigation, please get in touch today.
A whole new raft of penalties for VAT
“Plus ça change, plus c’est la même chose – the more things change, the more things stay the same”
HMRC continues with nudge approach
Over the last few years, HMRC has been using ‘nudge’ letters to promote and support their various compliance campaigns. Recent developments indicate that the system is set to continue.
An unwelcome Notice
The Follower Notice regime refers to a notice issued by HMRC to taxpayers who took part in avoidance schemes that have been determined by previous court rulings to be ineffective, the validity of these notices has come into question following a recent court case.
Tax Governance - a new fad?
Tax Governance is a “hot topic”, but what does it actually mean? Is it a topic of only passing interest or is it of significant importance here to stay?
Update on CCO with HMRC
3rd November 2020. Three years since the offence came into force, how comfortable are you that you have the correct procedures in place in respect of the Corporate Criminal Offence (CCO)?...
Corporate Criminal Offence
Failure to prevent the facilitation of tax evasion.
Alternative Dispute Resolution under a new light
HM Revenue and Customs (‘HMRC’) has announced two significant changes to the availability of Alternative Dispute Resolution (‘ADR’) in resolving disputes with taxpayers, which will have a major impact on the way in which disputes could be managed going forward.
Dispute Resolution Prevention Part 3
The Profit Diversion Compliance Facility (“PDCF”) was introduced in January 2019 in order for Multinational Entities (“MNE”) using arrangements targeted by Diverted Profit Tax (“DPT”) to have the chance to bring their UK tax affairs up to date.
Dispute Resolution Prevention Part 2
This article is the second of our Mutual Agreement Procedure (“MAP”) series and covers the effective use and benefits of arbitration available to taxpayers in international tax disputes.
Dispute Resolution Prevention Part 1
We believe that Mutual Agreement Procedure (MAP) is the most effective and efficient process available to taxpayers when looking to resolve double taxation due to the nature of the government-to-government negotiations and the focus on effective dispute resolution by the Organisation for Economic Cooperation and Development (OECD).
National contacts
David Lewis Director - Head of Tax Dispute Resolution (TDR)
