National Tax Investigations flyer CHSS
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The document discusses UK tax risk in the current climate of increased information sharing between countries. It summarizes Grant Thornton's expertise in dealing with HM Revenue and Customs (HMRC) inquiries across various tax areas. Their specialists are skilled at negotiating settlements with HMRC. Countries increasingly share financial information, making wealthy individuals more vulnerable to HMRC activity and uncertainty regarding managing personal and business affairs. Grant Thornton can help navigate this challenging environment and identify and manage tax risks.
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National Tax Investigations flyer CHSS
- 1. A Brave New World? UK tax risk in a hostile climate Our experts have a wealth of experience in dealing with HM Revenue and Customs (HMRC) enquiries. Particular areas where we have technical expertise are: ï‚· Complex personal return enquiries, including residence/domicile, cross border and offshore risks ï‚· Advising on Channel Island and Isle of Man wealth structures: analysing risk, resolving legacy issues and assisting with restructuring ï‚· Defence of tax mitigation and avoidance schemes ï‚· Identifying areas of tax risk and working to reduce risk profiles ï‚· Residence and domicile issues post 2008/09 for HNWI ï‚· Tax risk advice on pre-transaction planning ï‚· Responding to Schedule 36 information notices: first party or third party ï‚· Disclosure and discovery issues associated with tax returns ï‚· Making voluntary disclosures to HMRC ï‚· Achieving advantageous settlements through the Liechtenstein Disclosure Facility ï‚· Guidance on HMRC reviews, the tax Tribunal and Alternative Dispute Resolution ï‚· HMRC initiatives and targeted campaigns ï‚· The impact of information sharing between international tax regimes Our specialists are skilled in negotiating manageable settlements with HMRC across all taxes including income, corporation, capital gains, VAT and inheritance tax. Countries are increasingly sharing financial and tax information, such as through the recent UK- Swiss and UK-Isle of Man tax treaties, and wealthy individuals are particularly vulnerable to HMRC activity, to uncertainty about how to manage their personal and business affairs in this new, global era and to the reputational damage from HMRC enquiries. Grant Thornton's National Tax Investigations team can help navigate this new world. Our team includes several ex-HMRC investigators and we are specialists on how HMRC identifies, defines and tackles tax risk. We are also experienced in resolving disputes with HMRC. Whether you need a risk review, analysis of proposed arrangements or resolution of an HMRC enquiry, we can help identify and manage tax risk across all taxes, whether outside or during the HMRC enquiry process. We can also advise on the rare opportunities which still exist, such as the Liechtenstein Disclosure Facility.
- 2. • Have you considered your domicile position recently? • Are your assets structured in the best way to make use of your non-domicile status • Are you considering bringing offshore funds into the UK? • Are you aware of the new rules for high value residential properties? • Have you recenrtly bought or sold a high value property? • Have their been any changes in your personal situation which might affect your tax position in the UK? • Have you recently sold or are considering restructuring your business? • Have you recently come to the UK for work or are you planning on leaving the UK? • Are you aware of the new Statutory Residence Test applicable from 6 April 2013? • Do you know how this will affect your residence position? • Are you thinking of passing your wealth on and want to know more about the UK tax consequences of this? • Are you aware of your current potential UK inheritance tax liabililty? • Have you made or received any large gifts within the family? • Do you hold any trust structures? Passing on family wealth Residence Domicile Changes in your asset base How HMRC get information New hostile regime with information sharing between different countries Who deals with the information Offshore disclosure unit High Net Worth Unit Specialist Investigations Personal Tax International Trusts and Estates Large Business Service Anti- Avoidance Unit What HMRC do to you Enquiry and investigations Formal information requests Litigation The economic downturn has resulted in an increasingly hostile environment within which taxpayers must now operate. HM Revenue & Customs are increasing their activity and below we highlight some areas of interest to HMRC and show how the current climate leads through to HMRC activity. A changing environment
- 3. Offshore experience – client perspective "I have been a client of Grant Thornton for my personal tax returns for some years. A few years ago I inherited an offshore structure from my father, and I had an issue with HMRC concerning inheritance tax. I consulted Paul Roberts and the team and National Tax Investigations took a proactive approach to dealing with the queries raised by HMRC, including the preparation of a strong technical argument which took the whole structure outside the scope of UK inheritance tax and resolved the problem. I am most impressed with the innovative solutions and exceptional client service. I recommend them very highly indeed." Anonymous HMRC information requests A high net worth, non-domiciled individual was served a Schedule 36 information notice, requesting full bank statements for all non- UK bank accounts over a 3 year period. The client's concern was that HMRC were seeking to investigate their whole family, potentially damaging their privacy and reputation. Grant Thornton appealed the notice and successfully persuaded the HMRC review officer that the notice could not be used, due to promises given to Parliament about the uses of HMRC's formal powers. As a result Grant Thornton was able to defend the family's reputation as well as restricting the scope of HMRC's enquiries. Grant Thornton also worked with the client's two sets of legal representatives and leading Counsel to resolve the issue. Offshore experience – client perspective "I came to Grant Thornton with a legacy offshore tax issue. Their Tax Investigations team worked with their Personal Tax team to resolve the problem for previous years and to advise me on the best way to manage my affairs going forwards. this was done with professionalism and sensitivity at all levels, and, as a result, I have become a personal tax client of the firm." Anonymous Professional recommendations "I have worked with Grant Thornton’s UK Tax Investigation Team on several projects regarding disclosures over the last 5 years and have found their knowledge of the UK tax system to be excellent . They have always ensured that my clients privacy and interests were protected whilst seeking an innovative solution to the problems they faced. They have also always shown great empathy towards my clients and the confidence in their knowledge of the mechanics of HMRC helped put my clients at ease during what is a very stressful and upsetting time for them. I would gladly recommend the Tax Investigation Team of Grant Thornton to my peers and my colleagues as their knowledge of the UK tax system is outstanding and I am looking forward to a continuing collaboration in further projects." Anonymous, Swiss Lawyer Voluntary disclosures to HMRC Grant Thornton have significant experience advising clients on the UK-Swiss agreement and in guiding them through the Liechtenstein Disclosure Facility (LDF). We are also successful in framing voluntary disclosures to HMRC outside of these facilities, using our good relations with HMRC to find the appropriate teams to handle the disclosure and agree pragmatic terms of disclosure. Recently, we were able to agree a practical methodology with HMRC on a long-running non-UK trust with UK beneficiaries where capital gains in excess of £10m had been distributed , saving both tax costs and professional fees for the client. Discretion and negotiation A director of a PLC company approached Grant Thornton with a view to making a voluntary disclosure to HMRC in respect of personal undeclared receipts that had been solicited from his business contacts within the industry sector. HMRC's initial position was to include non-business receipts in the settlement, which could have led to tax liability in excess of £600,000. Grant Thornton carried out a discreet investigation of the client's private financial affairs, without compromising his status within his industry, resulting in a settlement of c. £350,000 which included tax, interest and penalties. Offshore experience – client perspective "We came to Grant Thornton for help in resolving a UK-based tax issue involving our multi-site family business and offshore personal assets. Grant Thornton were able to agree with HMRC that this situation could be handled through the LDF, providing us with protection from the risk of criminal prosecution as well as preferential terms. Grant Thornton were able to find a strong negotiating position with HMRC and we are very happy with the financial outcome achieved. Grant Thornton reached a pragmatic solution with HMRC, whilst respecting our family's circumstances at all times." Anonymous, LDF Client Case studies Client quotes
- 4. Contact us © 2014 Grant Thornton UK LLP. All rights reserved. 'Grant Thornton' refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or more member firms, as the context requires. Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd (GTIL). GTIL and the member firms are not a worldwide partnership. GTIL and each member firm is a separate legal entity. Services are delivered by the member firms. GTIL does not provide services to clients. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another's acts or omissions. This publication has been prepared only as a guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this publication. www.grant-thornton.co.uk Clare Halligan Executive T: +44 (0)20 7728 2813 E: clare.m.halligan@uk.gt.com Paul Roberts National Head of Tax Investigations T: +44 (0)20 7728 2777 E: paul.roberts@uk.gt.com Annis Lampard Senior Manager T: +44 (0)20 7728 3129 E: annis.lampard@uk.gt.com John Brassey Senior Manager T: +44 (0)20 7728 3189 E: john.h.brassey@uk.gt.com David Pedley Senior Manager T: +44 (0)121 232 5266 E: david.pedley@uk.gt.com Sukpreet Sangha Executive T: +44 (0)121 232 5181 E: sukpreet.k.sangha@uk.gt.com