Tax Investigations

Need to know…

COP8 and COP9

HMRC’s Fraud Investigation Service, formerly Specialist Investigations, undertakes investigations under Code of Practice 8 and Code of Practice 9. These are serious, invasive and time-consuming investigations that can have serious consequences if mishandled, including escalation to criminal investigation and prosecution. ETC Tax are experienced with dealing with technical investigations under COP8, as well as tax fraud investigations under COP9, liaising with HMRC throughout to bring matters to a conclusion as swiftly and with the least possible disruption to your client’s business.

Voluntary disclosures

HMRC has at their hands more and more sources of information meaning that the likelihood of tax irregularities going unnoticed has never been less. ETC Tax are experienced with HMRC disclosure opportunities and can assist with bringing up to date outstanding historic tax liabilities, helping to develop a disclosure strategy, minimising penalties and liaising with HMRC throughout the process to agree liabilities for your client.

Time to Pay Arrangements

Time to pay arrangements allow for the payment of personal and business tax debts to HMRC over a period, typically up to 12 months but potentially longer in exceptional circumstances. ETC Tax can provide guidance on HMRC’s likely stance in any specific case, assist with putting forward a proposal for HMRC’s consideration and ultimately with agreeing arrangements for your client.

Advance Payment Notices (APNs) and Follower Notices

Accelerated Payment Notices and Follower Notices have transformed the economics of avoidance, aiming to deny the cash flow advantage of participation in tax schemes pending the outcome of litigation. While it is not possible to appeal such notices, ETC Tax can advise on their validity, and where relevant, make representations to HMRC on your client’s behalf.