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

Tax Disputes 3.1 HMRC’S LITIGATION AND SETTLEMENTS STRATEGY This was published by HMRC in 2007 and has received much comment. Despite the emphasis put on the word “litigation” by many commentators, and the “no deals” emphasis by others, it is a “Litigation AND SETTLEMENTS strategy” and deals are still being done, especially where there are a number of issues in dispute with HMRC. 3.2 ENQUIRIES INTO TAX AVOIDANCE SCHEMES These will often be conducted by HMRC’s Anti-Avoidance Group (AAG) or by Special Civil Investigations (SCI) under Code of Practice 8. 3.3 APPEALS AND TAX TRIBUNALS I daresay that most accountants and tax advisers did not take up their profession because they believed that they had great advocacy or public speaking skills. However I have taken many appeals to a tax tribunal, as an Inspector of Taxes, and, in more recent years, representing the taxpayer. As an Inspector of Taxes I had the benefit of attending a five day residential training course, just on this subject - a luxury that could never be afforded by other organisations. So, I am not afraid of calling the taxman’s bluff and putting up instead of shutting up. 3.4 SECURING RELIEF FOR “ERROR OR MISTAKE” Although the time limits for claiming such relief are generally being reduced from 6 to 4 years, nevertheless, this is a valuable, and often over-looked or misunderstood, relief that is available if you find that you have overstated your income or under claimed tax reliefs. There are similar, and again often over-looked or misunderstood, rules that allow taxpayers to claim further reliefs etc out of time where HMRC discover further income as a result of an enquiry.

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