Guiding you & your business through disputes with HMRC.
Disputes with HMRC can arise for any number of reasons. There may have been a mistake which needs to be remedied; HMRC may want more evidence to substantiate your tax position; or there may be a disagreement over how the law should be applied.
A tax enquiry can be stressful and time-consuming, with the potential for financial and reputational costs for you and your business. You should be supported by trusted advisers who can guide you effectively through the process.
Our team advises wealthy individuals, owner managed businesses and entrepreneurs on dealing with disputes and investigations across all areas of tax. We have the expertise to handle disputes relating to the most complex aspects of personal and corporate tax. These include, for example, the remittance basis of taxation for non-domiciliaries, the taxation of offshore trusts and companies, tax arrangements for companies and individuals, including tax residence and domicile issues.
Our expertise encompasses the full range of UK taxes including income tax, capital gains tax, corporate tax, inheritance tax, stamp duty land tax and VAT. A substantial amount of the work we do involves a cross-border component.
We have significant experience providing guidance on all elements of the disputes process including HMRC’s powers, taxpayers’ rights, judicial review, tax-related penalties and the procedure for the specialist tax tribunals. One member of our team, James Austen, sits part-time as a Judge in the Tax Tribunal, hearing and determining appeals against decisions by HMRC in respect of both direct and indirect taxes. Our team also provides preventative advice so you can mitigate tax risk which may be associated with any proposed or existing arrangements.
We are committed to achieving the best outcome for you as a client. We gain a full understanding of your circumstances so we can provide solutions tailored to your specific situation. Using our in-depth knowledge HMRC practice and procedures, we always seek to negotiate a settlement which is cost effective and acceptable for both you and HMRC wherever possible. Taking a dispute to the Court or Tribunal should almost always be a last resort. However, in those cases where a settlement is either not possible or not desirable, we have the experience, ability and determination to proceed to litigation to protect our clients from attack by HMRC.
What is IR35?
IR35 was introduced by the Government to counter perceived tax avoidance where individuals were providing their services through an intermediary, such as a personal service company. From 6 April 2020 these rules expand to the private sector and, if IR35 applies, there can be significant tax consequences. Read our short summary of the key points and how to move towards compliance.