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...
03.04.2022Profile
Andrew is the Principal of TRRUK. Prior to setting up TRRUK he was a partner in City law firms where he developed a practice in contentious tax. His initial training in tax was in the old Inland Revenue (now HMRC [Her Majesty's Revenue and Customs]) which he entered via the Civil Service Selection Board.
He qualified as a Fully Trained Inspector of Taxes and, after initially working as a District Inspector in network offices, he was transferred in to the Revenue Special Compliance Office where he dealt with serious cases of suspected tax avoidance and tax evasion. He moved into private practice in 2000, working with a Big 4 accountancy firm before becoming a law firm partner.
Andrew represents both individual and corporate taxpayers.
More recently he has also represented professional advisers concerned about how to ensure they meet the requirements of the "Failure to Prevent Facilitation of Tax Evasion" legislation and their exposure to financial penalties and reputational damage from the two pieces of "enablers" legislation, one aimed at advisers in general and one with an offshore focus.
Clients come to Andrew in a variety of circumstances.
Some are under HMRC investigation and wish assistance in negotiations with HMRC and reaching a fair resolution. Some want advice on the exposure of their affairs to a future HMRC challenge and options for making their position more robust. Andrew also advises on where a voluntary disclosure to HMRC should be considered and the type of disclosure route most appropriate to the particular circumstances of the client. With the advent of CRS (the Common Reporting Standard) and the avalanche of information now available to HMRC, an increasing number of people are receiving so-called "nudge" letters and wish advice on how to react. Finally, with the various changes to the penalty legislation and the huge increase in the size and range of consequences, a number of clients may be prepared accept there is additional tax but query the degree of culpability claimed by HMRC.
In most instances the issues involved will be resolved by agreement with HMRC. However, where required, Andrew will advise on litigation. He is also a CEDR qualified mediator and has experience of taking cases through HMRC’s Alternative Dispute Resolution process.
While tax is often thought about as being about numbers, Andrew's experience is that tax consequences arise from how the many factors in people's lives interact with legislation and case law.
That means dealing with "tax" issues can sometimes involve discussions of sensitive personal and business matters. Andrew is conscious that he needs to earn the trust of each client. He also needs to understand the priorities of each client.
For many, the priority is achieving the lowest tax bill possible but for some there are competing concerns such as the length of time required to conclude the matter, the degree of certainty achieved or the risk of reputational consequences.
Andrew has written articles for various professional journals, has presented at conferences and has been interviewed on TV and radio on topical tax issues.
If you think TRRUK might help you, please do give Andrew a ring for an initial no-obligation conversation.
The new settlement opportunity for members of Eclipse Film LLP was reported in Taxation, 16 September 2021. The first part of this...
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