Tax enquiries, controversies and investigations - KPMG United Kingdom
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Tax Disputes and Investigations

Tax Disputes and Investigations

Reduce the stress of a tax investigation or having to make a voluntary disclosure to the tax authorities with the help of our expert advice.

We help with a tax investigation or making a voluntary disclosure to the tax authorities.

If you’re looking for guidance on any aspect of a tax dispute or investigation, call our helpline on 0800 970 9690 to set up a free meeting or talk to a specialist today.

It is clear the stakes have just been raised by HMRC in tackling offshore non-compliance. It is important that Requirement to Correct (RTC) is not seen as the domain of deliberate defaulters only. Anyone with offshore aspects to their UK tax affairs including non-residents liable to UK tax (e.g. offshore trustees and directors) should make use of the window available to review their position to determine whether a correction is required given the unprecedented sanctions that this legislation has introduced. 

Briefly, RTC:

  • Requires taxpayers who have outstanding UK tax liabilities that involve offshore non-compliance (offshore matters or offshore transfers) as at 5 April 2017 to correct the position on or before 30 September 2018
  • Applies to Income Tax, Capital Gains Tax and Inheritance Tax
  • Failure to Correct (FTC) penalty for those who do not correct by 30 September 2018
  • Standard Penalty is 200% of tax liability - can be lowered but not below 100%
  • Penalty applies regardless of behaviour giving rise to the original liability- e.g. deliberate, careless or where reasonable care was taken
  • 50% on top of Standard Penalty if “asset move” penalty invoked
  • No FTC penalty if person had reasonable excuse not to correct
  • Tax advice from an advisor who is an “interested person” disqualifies the reasonable excuse defence. As does relying on out of date advice
  • In more serious cases 10% asset based penalty and naming and shaming could also apply
  • Various methods to make a correction to HMRC - including use of Worldwide Disclosure Facility or notifying HMRC of position

RTC will be in point for any tax found to be due in the future (i.e. after 30 September 2018) for the relevant years (even where due to tax technical issues) through HMRC enquiries, Common Reporting Standard (CRS) exchange or otherwise discovered. No one needs to fall foul of the 100 - 200% penalties. RTC encourages sensible and precautionary risk assessment measures to be undertaken now. 

We can assist with:

  • RTC risk assessments to determine what inherent risks exist and areas of potential HMRC challenge (where review work could be undertaken to ensure the position is robust)
  • Tax planning implementation reviews
  • Assess whether a reasonable excuse defence could be advanced
  • Advice if a letter is received from HMRC enquiring into offshore assets and you are being asked to complete a certificate all is in order

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