Once you appoint me as your tax advisor I will ask you to sign a form 64-8. This authorises me as your tax agent to:
discuss your current and previous returns with HMRC
view and change your listed tax details, such as sources of income
provide bank details to HMRC when repayment is due
view and submit your updates (income and expenses)
finalise your overall tax position
view your calculations and amounts owed and paid
cancel your Self Assessment registration
access your Self Assessment details, such as your:
name
address
National Insurance Number
Unique Taxpayer Reference
HMRC has the right to check your tax affairs. If you are selected, you’ll receive an official HMRC investigation letter and I will receive a copy of the same. There are three types of tax investigation.
Random check: HMRC simply checks some Returns at random. This is usually a straightforward affair requiring a prompt and clear response. Delay or obfuscation, could result in HMRC making a full enquiry.
Aspect enquiry: Here HMRC will look at a particular aspect of your Return. Again, a swift and open response prevents the nature of the enquiry from spreading.
Full enquiry: During a full enquiry, HMRC will review the entirety of your records, usually because they believe that there is a significant risk of an error in your tax. In these cases I seek to isolate the cause of the enquiry and limit the questions to the specific areas of concern and address these.
Enquiries can initially be stressful on taxpayers and I take pride in bearing the full burden and resolving the matters positively and, as the circumstances allow, expeditiously.
I tend to be very robust in appealing HMRC penalties, particularly those resulting from the late submission of Returns. My success rate is very high.
I was one of the first tax professionals to take advantage of the Alternative Dispute Resolution (ADR) process introduced by HMRC in 2016. This is a process under which HMRC seeks to resolve ongoing disputes with taxpayers with a view to avoiding the cases being heard before a full tribunal. A HMRC mediator first reviews the arguments presented by the Tax Inspector and the taxpayer’s representative and then hears the arguments orally in an informal setting. The mediator then discusses the case with each party individually with a view to finding common ground, before the case is “relitigated” when the parties reconvene. All discussions are “Without Prejudice”. In this first ADR case I brought, I reduced the taxpayer’s “liability” to HMRC by £154,000. This was a back duty investigation bought by HMRC seeking to overturn tax assessments covering a twenty year period.
I have represented clients in negotiations with the Special Compliance Office. The SCO deals with cases of suspected fraud. Each special compliance case I brought was resolved on a pecuniary basis; that is, without prosecution. In one notable case resulted in my client settling a £4 million demand with a one-off payment of £400,000.
I have successfully represented clients before the tax tribunal, most notably Re Restorex discussed in the Profile section of this website.
I have prepared formal Tax Opinions for individuals and institutions appraising the validity of tax driven financial arrangements.