I defend individuals, businesses and companies who are under any sort of tax investigation or tax enquiry by H M Revenue and Customs (HMRC) or have any sort of tax dispute with HMRC.

26/03/2012 Update on UK/Swiss Tax Agreement - Inheritance Tax 15/12/2011 Swiss UK/Tax Agreement 19/09/2011 Wot! No News? 19/09/2011 Offshore Tax Evasion Penalties Doubled

HMRC Powers 4.1 PENALTIES Anything that you thought you knew about tax penalties will become redundant after 1April 2009 because of the introduction of Schedule 24 Finance Act 2007, with further revisions in Finance Act 2008. Actually that is not strictly true because the new penalties will only apply for accounting and return periods ending after 31 March 2008 so we will need to understand both the old rules and the new rules for some years yet. What is crucial in negotiating the level of penalty with HMRC is an as good, or better, understanding of the rules than the HMRC officer. 4.2 HMRC INFORMATION POWERS As an Inspector of Taxes, I used to say “the sources of information available to the Revenue are many and varied”. Not very helpful; but true. The rules governing HMRC’s powers in this tricky area have been completely re-written (in Schedule 36 Finance Act 2008). At the midnight hour on 31 March the old rules will disappear and the new rules will come into operation. And, guess what - do you think that the new rules give HMRC less powers or more powers? But there is some good news, the new rules are, by and large, the same for income tax, corporation tax, PAYE and VAT, so at least you don’t have 4 (more) sets of rules to look at. 4.3 COMPLAINTS AGAINST HMRC Most Inspectors of Taxes are decent, hard-working professionals. Indeed there are many past and present Inspectors who I count as friends. Their views might be at odds with the interests of my clients and the arguments get quite heated - but on a professional level, with a handshake afterwards. However, I have come across the occasional very badly worked case. HMRC recognise that such things can happen and will pay compensation where there has been a “serious error”. I have never been afraid to meet bad practice head on (in an assertive, but not aggressive manner). In one case where I followed the HMRC formal complaints procedure they paid out £30,000 in compensation.

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Having trouble with the Taxman? Would you like a free second opinion? From an ex-Inspector of Taxes