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 Enquires 2.1 INCOME TAX, CORPORATION TAX AND CAPITAL GAINS TAX ENQUIRIES Self Assessment (SA) enquiries under Section 9A and Section 12AC Taxes Management Act 1970 Code of Practice 1 Corporation Tax Self Assessment enquiries under paragraph 24 Schedule 18 Finance Act 1998 - Code of Practice 14. 2.2 PAYE AND NIC HMRC approaches to employers regarding PAYE, NIC, benefits in kind and “status enquiries” - Code of Practice 3. 2.3 VAT ENQUIRIES 2.4 HMRC INSPECTIONS From 1 April 2009, HMRC will be able to use Schedule 36 Finance Act 2008 to enter a person’s business premises and inspect the business premises, business assets and business records “if the inspection is reasonably required for the purpose of checking that person’s tax position”. “Tax position” is defined as including past, present and FUTURE liability to tax. At least seven days notice (not necessarily in writing) has to be given by HMRC but they can turn up unannounced if sanctioned by an “authorised officer” of HMRC. HMRC may copy, or even remove, documents which they inspect. 2.5 RISK ASSESSMENTS HMRC’s risk based approach to all enquiry work has been around for quite a while. However, formal “Risk Assessments” are a relatively recent concept. They cover not just Corporation Tax but VAT, Excise Duties and Employment Taxes. At the moment Risk Assessments are only made on “Large Businesses” (by the EU definition) ie companies with more than 250 employees or a turnover in excess of Euros 50m and Balance Sheet assets of Euros 43m. Curiously, only about 1000 Large Businesses are deal with by HMRC’s Large Business Service (LBS); the other 13,000 or so are dealt with by HMRC’s Local Compliance (Large Business Section). Confusing isn’t it? Anyway, LBS have appointed a Customer Relationship Manager (CRM) and a specialist team to each of their “customers” and have risk assessed all of them. We are told that 40% of those companies have been given a “low risk” assessment and should therefore receive a rather lighter touch from LBS as a result. A similar approach is now in the process of being carried out by Local Compliance on the largest of their Large Businesses. I can help you with this process by helping you to present your tax position at any meeting with the CRM (and their colleagues) and negotiating with HMRC to achieve the lowest risk rating possible.it? Anyway, LBS have appointed a Customer Relationship Manager (CRM) and a specialist team to each of their “customers” and have risk assessed all of them. We are told that 40% of those companies have been given a “low risk” assessment and should therefore receive a rather lighter touch from LBS as a result. A similar approach is now in the process of being carried out by Local Compliance on the largest of their Large Businesses. I can help you with this process by helping you to present your tax position at any meeting with the CRM (and their colleagues) and negotiating with HMRC to achieve the lowest risk rating possible.

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