London Tax Network Ltd is a specialist tax investigations and dispute resolution consultancy. We specialise in representing clients who are being investigated by HMRC or those who wish to make a disclosure. Our expertise means we know when HMRC are overstepping and our experience together with that of our wide network of experts means we can identify claims and reliefs that may have been overlooked previously.
We assist individuals directly or advisers from “behind the scenes”, whichever is preferable or more appropriate. Since incorporation in 2019, we have assisted with CoP9 investigations, s9A and National Minimum Wage enquiries, PAYE disclosures and provided advice through our network on international tax, SDLT and Customs Duty.
They say your Net Worth is your Network. Here at LTN, although we specialise in Tax Investigations, our wide Network means whatever the tax advice you seek, we will know the expert to provide it.
How can we help?
We specialise in the preparation of disclosures to HMRC and resolution of tax enquiries and Investigations including CoP9 (suspected fraud).
We have experience in a range of situations – self-employment, property, owner-managed businesses, non-UK domiciled individuals – and taxes; direct income taxes as well as PAYE, VAT and SDLT.
We understand that interventions by HMRC can be expensive, stressful, and intrusive. We take the stress out of the situation by resolving disputes swiftly and with a mutually agreeable settlement.
We liaise with HMRC and the client to respond to HMRC’s queries in a timely and appropriate manner, ensuring that responses are sufficient to allay HMRC’s concerns and with a view to resolution without delay.
Our expertise means we know when HMRC are overstepping their limits and how best to protect the client. We are also able to engage with advisers and assist them “behind the scenes” to resolve disputes.
Our Expertise
Enquiries and compliance checks
When a person has filed a return, HMRC generally have one year to open an enquiry, though the deadline is extended in certain situations. On looking at a tax return, HMRC may open an aspect enquiry - looking into a specific area of the return - or look at the return as a whole. It is important to ensure all queries are dealt with appropriately at the outset to ensure the enquiry doesn’t escalate and to ensure penalties are mitigated where possible.
Code of Practice 9 investigations (CoP9)
Enquiries and investigations are synonymous when it comes to HMRC. Typically though, investigations are more in depth and may cover a range of taxes and tax years. CoP9 refers to the procedure prescribed by HMRC for officers undertaking an investigation into suspected fraud. CoP9 investigations are civil in nature and rely on cooperation of the taxpayer to remain so. Without cooperation, the case may turn criminal and any sanctions will become more serious. LTN deal with CoP9 investigations on a routine basis and are well-equipped to deal with tax technical aspects as well as the formal process.
Information requests
HMRC’s powers to request documents and information are broad though there are certain safeguards taxpayers and their advisers need to be aware of. We review information requests to confirm whether what is requested falls within the bounds of legislation. In our experience, advisers and taxpayers can be wary of refusing HMRC’s requests for fear of the consequences. Our job is to protect the taxpayer and we do not hesitate to refuse a request if it falls outside the scope of the safeguards permitted by legislation.
Penalties and appeals
We are well versed in appealing tax penalties on a legislative basis as well as making claims for reliefs. Regarding penalties, the way the enquiry is dealt with throughout the process, together with the wording of any appeals with make all the difference in the world. We deal with penalties and appeals on a daily basis and understand that how the client's case is presented is key; in tax, there are very rarely any second chances.
Whitespace disclosure
When tax returns are filed, there are certain areas that may cause raised eyebrows at HMRC, for examples, unusual transactions, or significant fluctuations in expenses year on year. To mitigate the risk of an enquiry, we advise that appropriate disclosures are made on the whitespace of the tax return. Helpful disclosures will provide HMRC with sufficient information on any anomalies without giving the department more to question.
Voluntary disclosures to HMRC
When disclosures are made to HMRC, in many cases, it is not enough to simply complete a form and submit it. In order to accept the disclosure and close the case, HMRC need to have an understanding of the situation. We make disclosures on behalf of clients or guide clients through the process as appropriate, including a review of disclosures to highlight areas that may be queried. In this, as with many HMRC disputes, it is essential to include all appropriate information without providing irrelevant information that could lead to further questions. This is not always straightforward, and it can be useful to have an objective person prepare or review the disclosure.