
Gary Gardner
Partner
Tax Risk & Dispute Resolution
Specialist areas
- Advising on HMRC investigations into high net worth individuals, large businesses, and SMEs
- Experienced at assisting clients with making managed disclosures to HMRC in order to bring their UK affairs up to date, including using HMRC’s Worldwide Disclosure Facility (WDF)
- Experience of assisting corporate clients with making disclosures through HMRC’s Profit Diversion Compliance Facility (PDCF)Experience in dealing with cross-border tax enquiries, corporate residency/central management and control
- Expert in advising on the tax issues relating to permanent establishments (PEs), Transfer Pricing, diverted profits tax (DPT) and the Profit Diversion Compliance Facility.
- Expert adviser on investigations undertaken by HMRC’s Fraud Investigation Service, including the Contractual Disclosure Facility/COP9 and COP8.
- Experienced in litigation support and appeals to the First-tier Tax Tribunal, the Upper Tribunal and Higher Courts.
- Expert in the Corporate Criminal Offence of Failing to Prevent the Facilitation of Tax Fraud, including advising corporate clients on compliance and delivering training solutions.
- HMRC assessing powers, appeals, internal reviews and litigation
- HMRC’s statutory discretion
Services covered
I am based at
Covent Garden
Contact Gary
Insights

Top tips for taxpayers facing investigation
It is quite possible that taxpayers could still receive enquiry notices before the festive season gets into swing.

Domicile enquiries: HMRC’s approach and what taxpayers need to be aware of
Tax Risk & Dispute Resolution Partner Fiona Fernie takes a look at HMRC’s approach to domicile enquiries and what steps taxpayers should take.

Revisiting the Corporate Criminal Offences legislation
We review the Corporate Criminal Offences legislation and the compliance risks that many businesses are unknowingly exposing themselves to.