A succession of Court decisions and recent changes in legislation have resulted in the widespread failure of many marketed tax avoidance arrangements to achieve their intended tax benefits, due to HMRC’s draconian use of Accelerated Payment Notices and Follower Notices to pursue unpaid tax.

We advise scheme participators in agreeing exit terms with HMRC – including time to pay arrangements.

We can also assist in amending previous settlements with HMRC in the event that HMRC are required to change their position – for instance, further to the changes made to the Disguised Remuneration Loan Charge regime whereby sums previously paid in voluntary restitution are now reclaimable.