Tax Investigations

Tax Resolutions

We advise on HMRC enquiries, tax disclosures and tax disputes with a view to finding cost effective solutions.

Call our free confidential hotline

+44 (0)800 656 9990
We provide a comprehensive service to individuals, businesses and companies. Our relationship with you and your advisors is built on trust and mutual respect. We will always give you an honest appraisal of your position, including potential fees, whether it is favourable or not. Our team is accessible and approachable, and ready to answer your questions, giving you the confidence you need when dealing with a sensitive issue such as an HMRC enquiry or other tax dispute. Team leaders Sean Wakeman and John Cassidy are recognised as two of the leading practitioners dealing with investigations and disputes. To speak to us email [email protected]
Click here to see our regular spotlight, looking at the issues you may be facing and what action to take.

Our services

Contractual disclosure facility & COP9
If HMRC suspects fraud they will give you 60 days to make an initial  disclosure - expert advice should be quickly taken.
COP8
COP8 is used in where there has been significant loss of tax revenue but fraud is not suspected. 
Worldwide Disclosure Facility
A facility to make a voluntary disclosure relating to ‘offshore interests’.
Let Property Campaign 
Disclosing income for residential property landlords.
Cryptoasset disclosures
Have your Cryptoasset transactions been correctly reported to HMRC?
HMRC Enquiries
Potentially wide-ranging, including formal demands for data,  penalties, assessments, and visits to business premises.
Tax disclosure
We advise on HMRC enquiries, tax disclosures and tax disputes with a view to finding cost effective solutions.
Furlough grant and inaccuracies
HMRC will challenge any employer who has accidentally or deliberately overclaimed
support payments.
Criminal investigations
HMRC is increasingly using criminal investigations across a range of offences.     
Contractual disclosure facility & COP9
If HMRC suspects fraud they will give you 60 days to make an initial  disclosure - expert advice should be quickly taken.
COP8
COP8 is used in where there has been significant loss of tax revenue but fraud is not suspected. 
Worldwide Disclosure Facility
A facility to make a voluntary disclosure relating to ‘offshore interests’.
Let Property Campaign 
Disclosing income for residential property landlords.
Cryptoasset disclosures
Have your Cryptoasset transactions been correctly reported to HMRC?
HMRC Enquiries
Potentially wide-ranging, including formal demands for data,  penalties, assessments, and visits to business premises.
Tax disclosure
We advise on HMRC enquiries, tax disclosures and tax disputes with a view to finding cost effective solutions.
Furlough grant and inaccuracies
HMRC will challenge any employer who has accidentally or deliberately overclaimed
support payments.
Criminal investigations
HMRC is increasingly using criminal investigations across a range of offences.     

Case studies

Contractual Disclosure Facility
key finding nos oneWe were approached by another accountancy firm regarding their client, because HMRC had opened numerous enquiries into his companies and personal affairs, with no sign of resolution in sight. We reviewed the background and noted there were a number of transactions which were marked in the accounts as consultancy fees, whereas in reality the payments were received by the director into his personal accounts. We recommended our mutual client should make a request to participate in the Contractual Disclosure Facility in order to secure immunity from prosecution. We navigated our mutual client through the process, working closely with the referring accountant to establish the correct amount of tax that ought to have been paid. It was important for our client to resolve all historic issues in respect of multiple companies and personal tax issues as part of the process, which was achieved by way of contract settlement. We also negotiated the lowest possible penalty, suspension of penalties for the careless understatements and a time to pay arrangement. 

key findingAn individual who had deliberately failed to declare consultancy fees as well as operate PAYE on his housekeeper’s salary sought Crowe’s advice. Our client was an accountant, hence rightfully concerned that HMRC might seek to prosecute him for tax fraud. We recommended he make a request to participate in the Contractual Disclosure Facility in order to secure immunity from prosecution. Given the specific nature of the issues, Crowe managed to agree with HMRC that it would not be necessary to complete a full blown CDF report, which significantly reduced the amount of time and cost involved in reaching settlement with HMRC. 

key findings 3We were contacted by an individual who received an enquiry notice into a recent tax return. We noted that HMRC were asking some very specific questions indicative of there being suspicions that larger problems existed. While our client was initially reluctant to discuss the wider issues, we convinced him that it was in his best interests to make a full disclosure, not least because we had analysed publicly available data that pointed towards numerous issues which HMRC would of course already be aware of.  The client has since informed us there are numerous inaccuracies, which result in tax liabilities in excess of £1.5 million. We have therefore registered the client for the Contractual Disclosure Facility in order to protect him from prosecution. Furthermore, the act of making a full disclosure will ultimately reduce our client’s exposure to penalties.   

Worldwide Disclosure Facility

HMRC’s nudge letter campaign has resulted in numerous individuals and accountants getting in touch with Crowe for advice and support regarding how to make a full disclosure in respect of foreign income and gains. We have helped our clients navigate the complex rules in respect of how many years are assessable and what penalty rates will be applied.

We have also helped our clients ensure that a full disclosure is being made to HMRC in order to reduce the risk of follow up questions. One of the most important factors we have helped our clients with is determining whether there is a reasonable excuse for failing to correct their historic tax position before 30 September 2018, otherwise penalties ranging between 100-200% of the lost tax become due.

Furlough fraud and errors

A large organisation approached Crowe’s Employer Advisory Group (EAG) to discuss potential errors in respect of claims made via the Coronavirus Job Retention Scheme (CJRS).

The rules are extremely complicated and so there are numerous pitfalls which can reduce an employer’s entitlement to the funds. Our EAG colleagues identified a number of issues and worked closely with Tax Resolutions to make a disclosure to HMRC.

Great care was taken to provide explanations about why the mistakes arose in order to protect our client from the high penalties that can apply. We know from the recent budget that additional funding and HMRC officers will be made available to scrutinise and challenge claims made under the CJRS and the Self-Employment Income Support Scheme. We therefore recommend that professional advice is taken at the earliest opportunity.


Podcasts

 

In the final episode of our Tax Resolutions podcast series, Hayley Ives and John Cassidy talk us through ‘furlough fraud’ that has become apparent under the COVID-19 government support schemes. They focus on the complexities of the furlough fraud scheme, what happens when errors are uncovered and how the government are going about recouping wrongly claimed payments.

 
Financial Institution Notices
 

In this episode of our Tax Resolutions podcast series, Sean Wakeman and Hayley Ives give us a detailed summary of Financial Institution Notices (FIN). They discuss whether the concept of FIN is similar to third-party data requests, whether a financial institution can resist a notice and if concern has been expressed about HMRC’s enhanced powers. They also touch on the adverse effects this could have on taxpayers and why the notices need to be treated with care. 

 
Myths Surrounding HMRC Enquiries
 

In the next episode, Mark Ayre, Director and John Cassidy, Partner in our Tax Resolutions team talk us through some of the common myths surrounding #HMRC enquiries and highlight some key points that you should be on the lookout for. They also discuss what issues arise when moving towards the completion of an enquiry.

 
Code of Practice 8
 

In the next episode of our Tax Resolutions podcast series, Sean Wakeman, Partner, and Mark Ayre, Director, give us an overview of the Code of Practice 8 (COP8), explaining how it differs to a local tax office enquiry and what specific issues would usually come under the COP8.

 
Code of Practice 9
 

In the next episode of our Tax Resolutions podcast series, Sean Wakeman, Partner, and Mark Ayre, Director, discuss the Code of Practice 9 (COP9) and the ins and outs of the process. They cover how long an individual has to act on a COP9 letter, whether they are inclined to accept it and if going through the COP9 process makes an individual immune from prosecution.

 
Let Property Campaign
 

In this episode of our Tax Resolutions podcast series, Sean Wakeman, Partner, and Ian Shirley, Director, talk us through what the Let Property Campaign (LPC) is, who the facility is available to and how penalties under the facility work. They also discuss the advantages and disadvantages of using the LPC and if it is the right route for deliberate cases.

 
Worldwide Disclosure Facility

  

In this episode, Mark Ayre and Ian Shirley, Directors in our Tax Resolutions team give us an overview of what the Worldwide Disclosure Facility (WDF) is, how to go about making a disclosure and who qualifies to use it. They also discuss the best way to reduce a penalty and whether those with deliberate or fraudulent cases should still use the WDF.

Time Limits

 

John Cassidy, Partner and Hayley Ives, Director discuss time limits for HMRC to raise investigations. They cover the different time limits and categories for HMRC to raise assessments, the new rules for assessment windows in connection with offshore matters and explore the question of if additional tax is assessable, will this lead to a penalty?

Reasonable Excuses

 

In the first podcast of the series, Ian Shirley, Director and John Cassidy, Partner in our Tax Resolutions team cover the concept of ‘reasonable excuse’. They discuss what reasonable excuse is, why it is important to know whether your client did or did not have one and what HMRC’s stance is on reasonable excuse arguments. The team also share examples of where Crowe have recently argued reasonable excuse.

Webinars

HMRC’sannual accounts – smoke and mirrors?
Mark Ayre reviews HMRC's latest annual report and accounts, with a particular focus on its performance in relation to compliance issues and tax disputes.
Finance Act 2020: Coronavirus receipts and penalties 
John Cassidy, looks at the details of the Finance Act 2020, penalties and what this means for companies using the coronavirus job retention scheme. 
Top10 myths about HMRC enquiries
Join our webinar with John Cassidy, our resident myth buster when it comes to HMRC enquiries.
Avoidingtax professional negligence claims
John Cassidy provides some useful tips and advice on how to avoid claims of professional negligence regarding tax matters.
WorldwideDisclosure Facility
Sean Wakeman walks you through Worldwide Disclosure Facility and how it can be used effectively. 
LetProperty Campaign
Own rental property, but not sure how to disclose tax? Hayley explains HMRC’s Let Property Campaign, and how it can be used to correct past non-compliance.
Discovery Assessment
Discovery assessment
can be very complex, Mark Ayre explores the key points and latest developments. 
Reasonable excuse in an unreasonable world
John Cassidy unravels the mystery of 'reasonable excuse' and how it can
be used to reduce penalties issued by HMRC. 
Top10 tips on dealing with HMRC in lockdown
Sean Wakeman, National Head of Tax Resolutions, gives his top 10 tips on how to deal with HMRC while we are in lockdown. 
Reasonable excusein the real world
Ian Shirley brings reasonable excuse to life with examples of where they have been
successfully used.
HMRC’sannual accounts – smoke and mirrors?
Mark Ayre reviews HMRC's latest annual report and accounts, with a particular focus on its performance in relation to compliance issues and tax disputes.
Finance Act 2020: Coronavirus receipts and penalties 
John Cassidy, looks at the details of the Finance Act 2020, penalties and what this means for companies using the coronavirus job retention scheme. 
Top10 myths about HMRC enquiries
Join our webinar with John Cassidy, our resident myth buster when it comes to HMRC enquiries.
Avoidingtax professional negligence claims
John Cassidy provides some useful tips and advice on how to avoid claims of professional negligence regarding tax matters.
WorldwideDisclosure Facility
Sean Wakeman walks you through Worldwide Disclosure Facility and how it can be used effectively. 
LetProperty Campaign
Own rental property, but not sure how to disclose tax? Hayley explains HMRC’s Let Property Campaign, and how it can be used to correct past non-compliance.
Discovery Assessment
Discovery assessment
can be very complex, Mark Ayre explores the key points and latest developments. 
Reasonable excuse in an unreasonable world
John Cassidy unravels the mystery of 'reasonable excuse' and how it can
be used to reduce penalties issued by HMRC. 
Top10 tips on dealing with HMRC in lockdown
Sean Wakeman, National Head of Tax Resolutions, gives his top 10 tips on how to deal with HMRC while we are in lockdown. 
Reasonable excusein the real world
Ian Shirley brings reasonable excuse to life with examples of where they have been
successfully used.

Contact us

Sean Wakeman
Sean Wakeman
Partner, Head of Tax Resolutions
London
John Cassidy
John Cassidy
Partner, Tax Resolutions
London