Tax Avoidance Reviews
HMRC is devoting increasing resources to challenging anything that it perceives as aggressive tax avoidance. HMRC has so far won over three quarters of the cases it has taken to the Courts and it wants to deter taxpayers from entering into new schemes and to encourage those who are already participants to withdraw from them.
HMRC has an expanding range of powers in this regard, including:
- Ability to issue 90-day payment demands known as Accelerated Payment Notices (APNs) to individuals and companies participating in ‘notifiable’ marketed tax avoidance schemes.
- Ability to issue a Follower Notice requiring that a taxpayer amend their tax returns to remove any entries relating to a tax avoidance arrangement that HMRC considers has been proven ineffective in Court – either directly or as a result of a Judgement on another similar arrangement.
We can assist you in:
- Reviewing any marketed tax avoidance schemes or other complex arrangements that you have entered into.
- Advising on tax avoidance enquiries and settlement options – including how to withdraw from schemes as appropriate.
- Checking that HMRC has not exceeded its statutory time limits and discovery and enquiry powers.
- Explaining your options if you have received an APN or Follower Notice from HMRC – including your options for appeal.
- Negotiating Time to Pay arrangements.
- Advising you if you become subject to a ‘serial avoiders’ action by HMRC.