Tax Investigations

Case Study 1 - Multimillion pound retail business

HMRC opened a full corporation tax enquiry into a multimillion pound retailer with a number of high street outlets. The enquiry was complex and HMRC were seeking to demonstrate that there was a cash deficit in the business records, and the impact of this was that the potential tax assessments would have been a six figure sum.

We performed detailed reconstruction of cash reconciliations to demonstrate that HMRC’s calculations were flawed. HMRC eventually accepted that there was no corporation tax due and the case was closed.

Case Study 2 - Takeaway business

HMRC opened a full enquiry into a takeaway business and made assessments of around £70,000 for VAT and income tax. The enquiry was being dealt with by their accountant. We were approached to take over the enquiry.

We appealed the assessments and presented a detailed evidence based approach on the appeal with a business economics exercise model being presented together with a full rebuttal of HMRC’s assumptions. At the HMRC independent review stage the matter was concluded in our client’s favour and the case was settled for around £4,000.

Case Study 3 - Multimillion pound professional services firm

HMRC opened an aspect enquiry into a multimillion pound professional services firm. The enquiry was handled by their accountant and the enquiry reached an impasse as there were significant areas of disagreement with HMRC. The potential tax at stake was a large six figure sum. We were approached to take over the enquiry.

We took a fresh approach and had detailed meetings with the HMRC officer and departmental heads to understand the key areas of concern. We reconstructed the accounts using a scenario based approach and presented those to HMRC and this resulted in the case being settled and the tax was less than 10% of the initial amounts.

Case Study 4 - Assisting Accountants

We recently took over a matter which had been listed for a Tribunal hearing and the accountant had reached an impasse with HMRC. Despite initial strong opposition from HMRC for the matter to be reviewed ahead of the Tribunal hearing, as an independent party we successfully engaged with HMRC and persuaded them to have the case reviewed before the hearing, and achieved settlement at a small fraction of HMRC’s assessment.

Case Study 5 - Restaurant Business

We took over a tax enquiry matter for a restaurant business which was being dealt with by another firm of accountants. HMRC had made assessments of over £1million which had been reduced to £700,000 by the time the enquiry came to us. The matter had reached an impasse with HMRC and had been listed for a Tribunal hearing and the client faced bankruptcy,

We approached this matter with a fresh method of analysis and were able to reopen this matter with the inspector. There were a lot of deposits into the restaurant’s bank account which HMRC were arguing were from undeclared sales. We presented a case evidentially by tackling each transaction and demonstrated that these were from legitimate sources of money and not undeclared sales.

The case settled for less than £50,000, which was a small fraction of the initial amounts. We negotiated a payment plan and the client was able to settle the matter and avoided bankruptcy.

Criminal tax investigation case studies can be found here.