Tax Disputes and Investigations

Integrated and effective dispute resolution for high net worth individuals and their businesses

Understanding your needs

Media interest in the tax affairs of large businesses and wealthy individuals remains undiminished.

The Government and HM Revenue & Customs (HMRC) are under greater pressure to close the ‘tax gap’ by tackling evasion, tax avoidance and other non-compliance.

As a result, HMRC has increased the number of tax enquiries and the additional tax, interest and penalties collected from these. Dealing with tax investigations can be stressful, disruptive and expensive, and calls for effective tax dispute resolution.

R&D tax enquiries and dispute resolution

HMRC are increasing their focus on checking claims for R&D relief and Research and Development Expenditure Credits (RDEC). Checks are being carried out in as many as 20% of all claims made.

Paul Noble

Partner

View Paul's profile

If HMRC checks claims that your business has made, it’s important to act promptly to minimise the disruption caused and understand the risks posed. HMRC’s focus is to get businesses to demonstrate the nature of their qualifying activities and to justify the quantum of their claims.

HMRC’s activity includes:

Checking claims before making payments to claimants
Reviewing amended claims and Corporation Tax returns to understand the basis of claims
Undertaking criminal investigations where dishonesty is suspected

Ele Theochari talks to Paul Noble about HMRC activity around R&D Tax credit claims

Paul explains that HMRC have identified there is abuse in the system, there have been claims that are fraudulent or lacking in substance and that has caused them to ramp up their enforcement work in this area.

HMRC can start an enquiry into any claim either randomly or based on having intelligence information.

Our people, your partners

Our partner-led tax risk and dispute resolution team will work closely with you to provide innovative and client-focused solutions that will ensure your tax risks and any associated disputes, are effectively managed.

Drawing on our multi-disciplinary offering spanning personal tax, trusts and estates, corporate tax, VAT and business advisory services, we will ensure that your best interests are protected.

We align our expertise and experience to your business and personal objectives, ensuring each stage of a potential dispute is handled effectively to achieve a satisfactory conclusion.

How we can help

Dealing with HMRC enquiries can be time-consuming and stressful. Blick Rothenberg’s tax disputes and R&D experts can guide clients through the enquiry process allowing them to minimise disruption.

Our experts can help clients both proactively minimise risks and deal with HMRC enquiries should they arise. This can be achieved through the following:

Understanding and supporting the claim

Helping to understand the basis of a claim and review of systems and processes involved with capturing information to ensure they are adequately documented to support claims in the event of a HMRC enquiry.

Understanding HMRC

In the event of an enquiry, it is essential to understand HMRC’s tactics and powers in relation to assessment time limits and penalties.

It is also essential to Understand the HMRC enquiry framework and the risks this brings in order to advise on how to disclose any errors in a way that protects client interests.

From routine enquiries to in-depth investigations or assistance in bringing your UK tax affairs up to date through voluntary disclosure, we can guide you through every step of the process.

Our approach is tailored for your specific needs, to ensure we reach an early and favourable outcome.

Where we can help

HMRC enquiries
Specialist investigations & preparation of disclosure reports
Cross-border tax investigations
Global Automatic Exchange of Information & the Common Reporting Standard (CRS)
Voluntary disclosures (Worldwide Disclosure Facility and Disclosures outside of the former Facility)
Alternative dispute resolution
Appeals, postponement applications & HMRC internal reviews
Accelerated Payment Notices and Follower Notices
Tax litigation
Tax Tribunal support services
Managing tax and reputational risk
Managing HMRC relationships
Schedule 36 (part 5) FA 2008 notices
Time to pay arrangements
HMRC statutory discretion