Topics for Discussion

  1. Latest Compliance Issues
    • Current trends in HMRC activity
    • Problems being encountered and solutions found
    • Targeted trades
    • Offshore disclosures
    • Moving Forward
  2. CDF/COP9
    • Brief overview of the old position – pre and post 2005
    • The need for major change
    • The new regime – far sharper teeth
    • Better case selection
    • Outline, formal and voluntary disclosure procedures
    • Serious risk of criminal investigation or prosecution
    • The risks for the adviser
    • The LDF as an alternative
  3. VAT
    • VAT registration difficulties
    • Handling enquiries effectively
    • Errors & penalties
    • Written enquiries
    • Effective dispute resolution
    • Reconsideration, appeals and tribunal
  4. Dealing with HMRC meetings and information requests
    • HMRC Meetings – the different types and the rights and responsibilities of all concerned
    • Schedule 36 Information requests
    • Business Record Checks – the past and future
  5. Latest update and initiatives from HMRC
  6. Confessions of a Tax Investigations Specialist
    • Giving an outline as to how the case came about.
    • Disclosure (substantially complete) made within 4 months of opening challenge.
    • Importance of the issue of the fact sheets at the correct time.
    • Diversions-to off record bank accounts and to property. Interest from accounts and rents not disclosed.
    • HMRC contend that not only are the diverted profits ‘deliberate and concealed’ but also the bank interest and rents. This is challenged and HMRC take specialist advice and uphold my contention that the rents and interest is ‘deliberate’ only.
    • Subsequent year considerations.
    • Case straddles 1st. April 2010-considerations.
    • Other example (very quick) shows ‘reasonable’ care and no penalties exigible.