HM Revenue & Customs (HMRC) is continuing to offer new opportunities for UK taxpayers to disclose and regularise their historic tax issues. The most recent of these are the Jersey and Guernsey disclosure facilities and the Isle of Man disclosure facility. The approach from HMRC seems to be one of ‘carrot and stick’. The carrot is the opportunity to disclose and regularise historic issues in a way that’s relatively stress free and cost effective. The stick is the clear message from HMRC that if it discovers the issues before a disclosure is made then the consequences are likely to be severe. In this edition, we explore the carrot by looking in detail at the new disclosure facilities and the differences between them that can, in some circumstances, make a big difference on a client’s final liability. We also explore the stick in reviewing the recent announcements from HMRC and the Crown Prosecution Service around the desire to significantly increase the number of criminal tax prosecutions in the years ahead. We give an overview of recent developments in the use of alternative dispute resolution techniques to resolve outstanding issues. Our experience is that taking advantage of HMRC’s offerings in this area can prove to be a successful way in unblocking disputes that may have been stuck for some time. Finally, we explore the recent court decision on legal professional privilege in relation to advice provided by those outside of the legal profession. We also look at the need to make sure that the risks around carousel fraud are effectively managed for your clients.
Posted on: Tue, 23 Jul 2013 17:58:12 +0000
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