Alvarez & Marsal

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Tax Disputes and Investigations Services

A major tax investigation by HM Revenue and Customs (HMRC) - whether into allegations of serious tax fraud or into an avoidance arrangement - can have a seriously destabilising effect on any business. Diverting key leaders from their crucial roles of running the business and keeping it profitable can adversely affect relationships with banks, customers and suppliers.

HMRC has become more aggressive in its approach to compliance. Recent laws to give investigators more power in gaining access to business records and making unannounced visits to business premises represent a more confrontational attitude to business owners.

Recent Developments

HMRC has struck a deal with the Liechtenstein Government (the Liechtenstein Disclosure Facility) with the aim of uncovering by March 2015, all undisclosed funds in the names of UK taxpayers (read our Tax Advisor Update Alert).

The government announced in September 2010 that it will be ploughing £900 million into tackling tax evasion, fraud and avoidance through the following measures:

• Increasing the number of criminal prosecutions fivefold
• Setting up a new team to catch those hiding money offshore
• Focusing on high risk tax irregularities within large businesses
• Using more private sector debt collection agencies
• Using more registration checks to stop people claiming tax repayments when they are not due

The notification deadline for the New Disclosure Opportunity (read our Tax Advisor Update Alert) an "amnesty" in relation to offshore accounts has now closed. HMRC is reviewing information received from over 305 banks in the UK with offshore services. HMRC will still accept voluntary disclosures for reduced penalties. Call our confidential hotline for more information: +44 (0) 77 7022 1051.

The notification deadline for the Tax Health Plan, an "amnesty" aimed at GMC registered medical professionals and dentists has now closed (read our ALERT: HMRC Issues Disclosure Opportunity for Medical Professionals). HMRC is reviewing information received from medical insurers and other medical professionals within the same practice. HMRC will still accept voluntary disclosures for reduced penalties. Call our confidential hotline for more information: +44 (0) 77 7022 1051.

Since 1 April 2010, HMRC is able to "name and shame" serious tax defaulters on its website when it discovers a taxpayer has "deliberately" underpaid tax of more than £25,000.

Our Team

Alvarez & Marsal Taxand UK brings a dedicated Tax Disputes and Investigations team, including former HMRC inspectors, to offer highly experienced support in quickly concluding investigations. Our goal is to minimise the tax at risk and keep penalties and interest to an absolute minimum.

Our Tax Disputes and Investigations professionals assist in situations such as:

• Specialist Investigations or a Civil Investigation of Fraud under Code of Practice 9
• "Dawn raids," possibly involving arrests and detention
• Invitations to an interview under caution
• Orders to produce documents
• Implemented avoidance schemes
• Concerns over residence / domicile status
• Unprompted disclosure of irregularities
• In-depth enquiries
• Potentially contentious appeal hearings