We often advise on strategy across all proceedings ( and anticipated proceedings), including on whether to seek a stay, communication and negotiations with the other side, interview tactics and correspondence.
These are often high stakes and of key importance to the business and/or individual that is faced with a potential investigation.
Our core areas of expertise include:
Exercise of HMRC Functions & Powers
We can assist in challenging the exercise of those functions and powers, in particular: searches pursuant to warrants, account freezing orders, schedule 36 FA 2008 information notices, the imposition of penalties, and accelerated payment notices.
Failure to Prevent the Facilitation of Tax Evasion
We assist in developing reasonable prevention procedures as a defence to the corporate offence under CFA 2017 and can advise on self-reporting and/or responding to any investigation.
Criminal Investigations
Matters in which accountants wish to continue to advise the existing corporate or individual client. We advise on communication and negotiation with investigators, interview tactics and correspondence, and we address any issues relating to risk of restraint and account freezing.
Tax Irregularities
When irregularities are raised by an existing corporate or individual client or whistleblower; or discovered by ordinary accounting advice, we assist in the strategic response to avoid a criminal outcome, mitigate tax penalties, and can assist accountants in the maintenance of the relationship between the client and HMRC
HMRC Inquiries
Matters which might lead to an appeal to the First-tier Tribunal/Upper Tribunal. We provide early assistance to address potential serious risks, and can function as a buffer between accountants and HMRC
Internal Investigations
We regularly advise on the conduct of internal tax investigations and any consequences, including as to procedure, disclosure, and the approach to privileged material
Tax Appeals & Judicial Review
We often represent clients in proceedings before the First-Tier Tribunal, Upper Tribunal, Crown Court, High Court, and Court of Appeal
“The clerks always go above and beyond to assist. They understand the needs of instructing solicitors, particularly in identifying suitable counsel for cases” | Chambers & Partners
