Tax Dispute Resolution
Often, the key to a successful resolution is more about knowing how to present facts and scenarios to HM Revenue & Customs in a form that will enable an acceptable settlement to be made.
Tax Dispute Resolution
Opus Pear Tree’s tax dispute resolution service utilises our expertise in forensic accounting, investigation, corporate intelligence, and litigation to provide assistance to a wide range of individuals, business owners, accountants, lawyers and other professional clients in both civil and criminal cases.
HMRC has a wide range of powers to investigate personal and business tax affairs, from entering premises without notice to obtain documents relevant to your tax affairs to penalty regimes to maximise the collection of allegedly deliberately underpaid duties. We can negotiate cost-effective and pragmatic settlements, enabling clients to continue operating their business throughout the onerous process of the enquiry.
HMRC are increasingly supporting the appointment of insolvency practitioners to recover tax they believe to be unpaid by companies and individuals. Insolvency practitioners can seek to recover funds from former directors, shareholders and other individuals of influence in the company. Our team are experienced in negotiating the most favourable settlement terms with both HMRC and/or insolvency practitioners.
We offer litigation support and tax specialists to prepare defences and attend alternative dispute resolution or court hearings to defend clients against cases of disputed tax assessments or alleged fraud brought by HMRC.
Case examples of our work
Assignment 1: HMRC demanding settlement of PAYE
A client was personally subject to a PAYE determination of over £3m. We reassessed the calculations and represented the client at a meeting with HMRC, whereby we were able to reduce the liability to nil.
Advice on tax disputes
As well as an overall wealth of knowledge and experience in this area, the team includes an ex-HMRC Officer who can advise on the best path to resolving a dispute. If you would like to speak to Opus about our dispute resolution services, please contact our Director, Liz Coleman.
Shareholder dispute requires independent valuation
“My client was involved in a shareholder dispute in the online ticketing industry and needed a valuation prepared in order to inform its settlement decisions ahead of a without prejudice meeting, and to provide us with ammunition to use during negotiations. Nicholas responded quickly to the brief and let us have a number of options as to how to approach the valuation. As a result of that we asked Nicholas to prepare two valuations at different points in time in order to effectively demonstrate both (1) the losses that our client had suffered as a result of the counterparty’s conduct; and (2) the current valuation of the company. Nicholas prepared the report on time and on budget. He clearly explained the basis of his valuations so that we were able to put across persuasive points during the negotiations, and he was on hand to assist us when new facts arose during the negotiations. The matter successfully settled some time after the initial without prejudice meeting, and I would not hesitate to use him again in the future”