Mark Ayre

Mark Ayre

Director of Tax Disputes and Investigations
London

I am a Director in the Tax Disputes and Investigations Team of Crowe UK. I work with a range of clients, such as limited companies, directors, sole traders and individuals and specialise in assisting them with all types of direct tax investigation, providing expert advice in cases ranging from HMRC Compliance Checks through to investigations into cases of suspected fraud (Code of Practice 9 and the Contractual Disclosure Facility).

I have extensive experience in guiding clients through the process of a voluntary tax disclosure, from a technical review of the underlying facts, presenting them to HMRC in the most appropriate manner and negotiating settlement.

I also assist clients with appeals against HMRC decisions and have experience in utilising HMRC’s Alternative Dispute Resolution (ADR) process to resolve disputes.

Prior to joining public practice I was an Inspector of Taxes at HMRC, where I spent eight years undertaking investigations into a number of individuals, partnerships and companies.


What I do

  • HMRC tax enquiries, investigations and compliance checks
  • COP9 fraud investigations under the Contractual Disclosure Facility and COP8 investigations
  • Voluntary tax disclosures to HMRC, including disclosures under domestic and offshore campaigns such as the Let Property Campaign (LPC) and the Worldwide Disclosure Facility (WDF) 
  • Technical advice on HMRC powers, including information powers, discovery assessments and penalties
  • Appeals against HMRC decisions up to the Tax Tribunal
  • Alternative Dispute Resolution (ADR)

My Clients

  • Companies and their Directors
  • Sole traders, Partnerships & Owner-Managed Businesses
  • Individuals
  • Landlords
  • Professional advisers

My Insights

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HMRCs AI ambitions
HMRC’s AI push promises efficiency and fraud detection but raises questions over the balance between automation and human judegment.