Film Partnerships: Eclipsing the Litigation and Settlement Strategy
The new settlement opportunity for members of Eclipse Film LLP was reported in Taxation, 16 September 2021. The first part of this...
03.04.2022- Investigations under HMRC's specialist Codes of Practice. e.g. COPs 8 & 9
- Investigations under HMRC's Offshore, Corporate and Wealthy team
- Investigations under HMRC Large Business
- Disclosures under the various disclosure opportunities
- Dealing with HMRC Debt Management, e.g. Time-To-Pay arrangements
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Advice to corporates on Tax Risk Policy including:
- Full tax risk policy including ”cooperative compliance”
- Policy focusing on protocol to evidence Central Management and Control not in UK
- Policy to review Personal Service Companies in light of IR 35 requirements
- Tax issues arising from Divorce
- Advice on UK residence and UK domicile
- Advice on status (employment versus self-employment)
- Disguised Remuneration Settlements Opportunity (and interaction with Loan Charge legislation)
- Accelerated Payment Notices
- Appeals on culpability
- Advice on Requirement to Correct Offshore Non-Compliance legislation with disclosures as appropriate
- Taking cases to litigation and instructing Counsel
- Taking cases through HMRC's Alternative Dispute Resolution process
- Advice to UK accountant on Penalties for Enablers of Defeated Avoidance legislation and interaction with GAAR
- Advice to offshore trustee on Penalties for Enablers of Offshore Non-compliance legislation
