IMPORTANT INFORMATION – COVID-19 UPDATE

We have over the last several months noticed an increase in HMRC Code of practice 9 (“COP9”) investigations following a recent reorganisation of HMRCs Fraud Investigation Service. COP9, is a serious civil investigation designed to encourage taxpayers to disclose their tax positions or face potential criminal investigation and prosecution. The increase in the number of COP9 investigations underscores HMRC’s commitment to tackling tax evasion and ensuring tax compliance in the UK.

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In this Pannu Tax update, we explore HMRCs recently announced Remuneration Trust Settlement Opportunity (“RTSO”). If you have a client who has an outstanding remuneration trust arrangement, you should read this..

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In this Pannu Tax update, we review HMRCs Alternative Dispute Resolution (ADR) process and share our recent experiences and tips on how to achieve the best outcome for clients.

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Welcome to our first update of 2020 of what's new and relevant in the world of HMRC, tax disputes and investigations. 20 December 2019 saw publication of the eagerly awaited report by Sir Amyas Morse on the 2019 Loan Charge provisions following his independent review, together with the Government's response.

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A lot has already been written about the new 'Requirement to Correct' provisions coming into effect on 30 September 2018. In brief, the legislation introduced in last year's Finance (No 2) Act requires taxpayers to disclose outstanding undeclared offshore liabilities for income tax, CGT and IHT to HMRC before 30 September 2018 or face draconian penalties in the range 100% to 200% of the tax involved.

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While HMRCs drive to tackle evasion and avoidance may be old news, it looks as though we are now seeing a further ramping up of compliance activity and investigations from HMRC elite investigation units: Specialist Investigations ("SI") and the Fraud Investigation Service "FIS").

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