Complex technical investigations

We manage and resolve complex HMRC technical investigations – including those involving international corporate and trust structures and wealthy “non-doms”.  We work closely and liaise with all other professional advisors – including the existing accountants, lawyers, wealth managers, family offices, trustees and executors as appropriate.

Because of the complexity, and the large amounts of tax involved, these investigations are typically conducted by HMRC Fraud Investigation Service (“FIS”) but if fraud is not formally suspected – and in the event no suspected fraud comes to light – they are conducted as technical investigations under HMRC Code of Practice 8 (“COP 8”) rather than under HMRC Code of Practice 9 (“COP 9”).

These investigations can be into particular tax avoidance arrangements, or they can be broad ranging and simultaneously involve multiple members of the same family, the family’s companies and trusts in the UK and overseas, and the executors of deceased family members.  Depending upon the circumstances, investigations can go back many years and run for a considerable period – requiring careful expert management at every stage to ensure that all information is appropriately and consistently presented, and that maximum mitigation of any penalties is ultimately achieved for cooperation.

At the outset, we meet with HMRC to understand the nature of HMRC’s concerns and to agree the scope of the work required to address those concerns.  We then work with taxpayers and their professional advisors to obtain the information needed, we review it and form our own conclusions of the tax consequences and report to HMRC setting out the background and our findings.  We then liaise and negotiate with HMRC to achieve a fair settlement of any outstanding tax liabilities and any penalties.