Settlement with HMRC
For many, HMRC’s aggressive campaign has resulted in years of uncertainty and worry following multiple communications, often years apart, of varying complexity, hostility and more lately accuracy.
Where this is the case, full and final settlement through one of HMRC’s settlement opportunities may seem an attractive proposition. It is important that the settlement is built on fair and robust principles which, in our experience, is often lacking.
Documentation and calculations need to be checked for accuracy, adherence to legal process, penalty provision, valid notice periods and full confirmation that future liability is removed. WTT often challenges HMRC offering a differing analysis built on facts, interpretation, tax legislation and common law principles to seek a reduced settlement position.
Following a settlement, it is important to seek an exit from the structure in a way which protects future tax positions. WTT has formulated methods for exiting schemes in this way.
For further information on practical application of an exit please to contact us.
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