Expert Guidance for Navigating HMRC Processes

Our experienced team offers comprehensive support in managing HMRC investigations, disclosures, and disputes. We provide strategic direction, leverage our deep technical expertise, and work closely with clients to ensure efficient and fair outcomes.

OUR SERVICES

Whether you’re an individual, business, or professional adviser, we have the skills and knowledge to help you navigate HMRC’s complex landscape.

Managing HMRC Investigations

HMRC Investigations, compliance checks and enquiries can be stressful, lengthy, and burdensome to deal with. The best professional advice and support can help manage and minimise each of these issues whilst securing the right outcome for you and your business.

Making Disclosures to HMRC

Tax errors and irregularities can arise in a very broad range of circumstances. In most cases the best way to deal with these issues is to engage with HMRC and make a disclosure to put things right.

Resolving Disputes with HMRC

HMRC disputes can be time consuming, costly, and unsettling. A typical HMRC enquiry can last for more than 12 months, and some can go on for many years. Resolving disputes with HMRC has become increasingly difficult in recent years as they have introduced new and more complicated governance procedures which need to be addressed.

Services for Professional Advisers

We frequently work with other professional advisers to help manage their clients’ disputes with HMRC. We are often asked to assist where advisers recognise that disputes are sufficiently complex or serious to require specialist input. We can work with you flexibly depending on your requirements, providing advice and support on an ad hoc basis, working alongside you, or managing the totality of a dispute for your clients depending on your preference.

Proactively Managing Tax Risk

Management of tax risk is a requirement of a number of legislative and regulatory regimes affecting companies, trustees, partnerships, and individuals. In addition, effective management of tax risk can make a valuable contribution to delivering a business or trust’s wider strategy.

Advising on HMRC Powers and Procedures

HMRC’s power and procedures are a complex, deep specialist technical area of tax.

In our experience, it is easy for non-specialist accountants and tax professionals to overlook key points or otherwise make mistakes in this area, which is one they will not come across regularly in their day to day work.

Managing HMRC Investigations

Our people are hugely experienced in resolving all kinds of disputes with HMRC and our team includes former senior HMRC investigators.

We can provide strategic direction and management of the process to ensure it is quicker, leaner, and more efficient.

We are skilled at improving the interactions with HMRC and maintain an extensive network of contacts that we can leverage.

We will help you understand and navigate HMRC governance processes to achieve settlement.

We can negotiate and agree payment terms to suit your plans and circumstances.

We understand and can manage the use of HMRC powers to ensure you are treated fairly and do not pay more than is due.

As deep specialists we frequently support accountants, lawyers, and other professionals whose clients are involved in particularly complex or difficult HMRC disputes.

We work with individuals, companies, partnerships, and trusts and are experienced in all kinds of HMRC investigations including –

Tax avoidance schemes

HMRC code of practice 8 and 9 (‘COP 8’ and ‘COP 9’) enquiries

Offshore matters

Residence and domicile / non-dom

Employer issues including PAYE

HMRC nudge letters and task force campaigns

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Making Disclosures to HMRC

HMRC may prompt a taxpayer to make a disclosure based on information they hold, or a taxpayer may make an unprompted disclosure after identifying an issue. In either situation, it is imperative that the initial contact with HMRC is carefully considered. This will set the tone for how the whole process will be managed and is key to ensuring the optimum outcome.

There are several established HMRC facilities that can be used for making a disclosure of tax irregularities.
These include:

Contractual Disclosure Facility ‘CDF’

The CDF is used to for disclosures made under Code of Practice 9 in relation to suspected tax fraud.

Worldwide Disclosure Facility ‘WDF’

HMRC’s digital service for taxpayers to make disclosures about overseas interests.

Digital Disclosure Service ‘DDS’

The DDS can be used to disclose irregularities relating to most taxes with the exception of VAT.

Profit Diversion Compliance Facility ‘PDCF’

A facility for multinational businesses affected by Diverted Profits Tax to bring their tax affairs up to date.

Each facility has its own specific requirements and process to follow. We help clients successfully navigate these facilities and reach settlements with HMRC.

In addition to the established disclosure facilities, there are also dedicated teams within HMRC that deal with specific areas of interest, for example a piece of tax planning or a risk identified in a particular business sector. We assess every case carefully to ensure that disclosures are presented to HMRC in the correct manner and using the most suitable facility.

Once the initial approach is made, managing a disclosure requires a clear understanding of the matters which HMRC will need to be addressed and the information which they will require.

Informed by our deep understanding of the relevant legislation and HMRC practices, we can help clients and their advisers to ensure that disclosures are made efficiently and with the minimum of stress.

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Resolving Disputes with HMRC

Our team of experienced tax dispute professionals can provide support to help resolve disputes as quickly and efficiently as possible. Our team can review a dispute and the underlying issues with a fresh pair of eyes, including carrying out a review to ensure that there are no procedural defects in HMRC’s case.

We will help you navigate HMRC’s governance processes in order to ensure that management of the dispute is as efficient as possible and that you understand why HMRC are taking particular positions.

We can utilise HMRC’s Alternative Dispute Resolution (‘ADR’) process as a mechanism to reach settlement, including making applications for ADR and steering you through the process.

We can help to prepare for litigation in appropriate cases where an agreed settlement is not possible, including collating necessary evidence and instructing and liaising with Counsel.

We will work with you to address the cashflow implications of settlement with HMRC by reaching agreement on the best possible payment terms.

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Services for Professional Advisers

We frequently work as part of a team alongside other tax advisers, accountants, solicitors, trustees, and insolvency practitioners and find that a collaborative approach to resolving disputes where a team of advisers bring different complementary specialisms can reap significant benefits.

Our approach enables professional advisers to maintain and enhance client relationships in what might otherwise be difficult circumstances as well as managing risk.

We can also provide expert witness services in appropriate circumstances.

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Proactively Managing Tax Risk

In our experience, where clients often encounter difficulty in this area is in identifying an adviser who can recommend and support the implementation of practical, efficient measures that will satisfy legal and regulatory requirements and support the wider strategy without being excessive, impractical and restrictive.

We are experienced in delivering bespoke solutions tailored to your business or organisation’s circumstances across all areas of tax risk management, including:

Trust structures, both existing and acquisition due diligence

Trustees’ own tax and fiduciary obligations, separate to those of their clients

Historic personal and corporate structures

Tax due diligence

Individual and corporate tax residence, domicile, and permanent establishment

HMRC clearances, rulings, and advance agreements

Tax risk assessment of transactions

Criminal Finance Act (‘CFA’) corporate criminal offence (‘CCO’) risk reviews

Senior Accounting Officer (‘SAO’) obligations

HMRC Business Risk Review Plus (‘BRR+’) preparation and conduct

Transfer Pricing and international tax reviews

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Advising on HMRC Powers and Procedures

The best specialist advice and support in this area is essential for successful engagement with HMRC and resolution and settlement of disputes.

We have deep specialist expertise and experience across all areas of HMRC powers and procedures, including:.

Penalties

Challenge, Mitigation, and Suspension

Assessments

There are a large number of different types of assessment powers available to HMRC, each with their own time limits and gateway requirements for HMRC to be able to bring tax for past years into charge

Information powers

This is another technically complex area with a wide variety of powers available to HMRC, and an equally complex set of factors to be considered in deciding whether and how you should comply with HMRC’s demands. Understanding and not underestimating HMRC’s ability to access information is crucial in arriving at a successful strategy for resolving disputes and in minimising the time, cost, and disruption of doing so

Exchange of Information (‘EoI’)

HMRC has the most extensive tax treaty network of any country and is often able to access documents and information held overseas through partnerships with the local tax authority

Accelerated Payment Notices (‘APN’)

A key power in HMRC’s campaigns against marketed tax avoidance schemes which can bring discussions over payment terms into play much earlier in the process than used to be the case

Follower notices

Another key power in HMRC’s campaigns against marketed tax avoidance schemes which seeks to apply the conclusions of similar schemes HMRC has successfully litigated to others