United Kingdom

Tax Settlements and Investigations 

HMRC is entitled to check your tax return irrespective of whether you are an individual, partnership, company, employer/employee or trustee. It is focussing its core resources on areas of identified risk where appropriate using a multidisciplinary approach across all taxes. Enquiries can range from routine to very serious and intrusive. Issues arising may be resolved easily, or may be highly contentious requiring concerted effort or litigation to resolve.

What's on your Mind?

 

  • I have received an HMRC enquiry, what has given rise to the enquiry and what should I do next?  
  • What information and documents are HMRC entitled to see, is such a request reasonable and does HMRC have reasonable grounds for asserting that there are errors in my tax returns?
  • HMRC have asked how robust my business' systems, processes and controls are, how do I deal with this?
  • I am aware from recent press coverage of increasing interest in offshore issues. How do I obtain reassurance that my affairs are in order?
  • What are the best solutions to long-running tax enquiries and what options are available to me?

 

Bringing you Peace of Mind

 

  • We help companies, employers, individuals, trustees, solicitors, accountants and other advisors navigate through the demanding process of an HMRC investigation.
  • We manage everything from HMRC local investigations to HMRC Large Business Service and specialist investigations unit enquiries into suspected tax avoidance and evasion under Code or Practice 8 and 9.
  • We also provide a helpline for people with undisclosed liabilities connected with offshore accounts.
  • We can act as your representative with HMRC, and we can act as a mediator to bring both sides together constructively.

 

What's in it for you?

 

  • Earlier resolution than would otherwise be the case.
  • An outcome which reflects the client's interests and maintains appropriate relations with HMRC.
  • Reassurance through regular and clear communication so you feel in control.

 

Why KPMG

 

  • Our teams are led by senior ex HMRC inspectors who use their exceptional skills and experience to help you manage tax risk.
  • We use our experience and credibility to develop productive relationships with tax authorities and deal with contentious tax enquiries, enabling us to manage the end to end investigation process effectively.

 

Case Study

 

Case Study 1.

 

  • Our client had previously been through a HMRC Serious Fraud investigation. During follow up compliance work further irregularities were indentified which put the company directors at serious risk of prosecution.
  • We prepared an extensive disclosure document which was submitted to HMRC. This approach to HMRC was fundamental in HMRC's decision to adopt a civil settlement process rather than commence a criminal investigation, effectively securing the company directors immunity from prosecution.

 

Case Study 2.

 

  • A global consumer products group acquired a group with a legacy of tax planning structures that were under enquiry with HMRC. The acquiring group wanted to progress the enquiries to resolution quickly whilst securing maximum value.
  • The new Parent group required certainty on availability of substantial losses within the acquired group. Both the client and HMRC wanted an improved relationship and risk rating for the acquired group. We worked with the parent group to prepare a business case to identify the value that could be obtained through resolution on a negotiated settlement basis.
  • We worked with the acquired group and HMRC to development and implement a legacy settlement project.
  • Our team acted as the interface with HMRC on several levels - strategic oversight, project management and technical resource.
  • The project resolved 18 significant direct and indirect tax issues spanning several years. The client secured a £42m benefit from a negotiated settlement with HMRC compared to a litigation option resulting in approximately £200m release of provisions.
  • The client received a greatly improved risk assessment and worked with HMRC to develop and implement a new working relationship designed to give both parties earlier certainty on emerging tax issues.
  • Our holistic approach aims to gain clients credit for resolving difficult disputes collaboratively with HMRC. Our approach has demonstrated we can facilitate the resolution of contentious issues whilst enabling clients to stay in control and enhance their reputation with both internal and external stakeholders.

 

 

Contact

Paul HarrisonPaul Harrison

Partner

KPMG in the UK

 

020 7311 3053

Email Paul

Get in touch with KPMG

Liechtenstein Disclosure Facility

The Liechtenstein Disclosure Facility (LDF) provides a framework for the disclosure of irregularities connected with overseas assets held anywhere in the world with unique benefits and on favourable terms.

 

UK / Switzerland Tax Agreement

    On 24 August the UK and Swiss governments provided further detail about the bilateral agreement for UK residents to disclose and/or resolve outstanding tax issues with regard to existing banking relationships in Switzerland. The agreement is expected to enter into force from 1 January 2013. Read more.

     

On 31 March, KPMG's Paul Harrison chaired a Tax Journal round-table on the topic of dispute resolution, attended by Dave Hartnett (HMRC) and leading representatives from the industry (Shell) and professional services (McGrigors).

 

 

 

To find out more about Tax Disputes Resolution and how we can help you visit our dedicated webpage.