David Richardson, the director of HMRC’s Counter Avoidance Directorate, has been setting out an increased pace of scrutiny and investigation into participants in tax avoidance schemes.
In letters recently issued, he writes:
‘The Serial Avoiders Unit (SAU) within Counter Avoidance concentrates on serial avoiders – those whose participation in multiple, convoluted schemes demands urgent and intensive scrutiny. The team’s focus on your tax affairs starts now, with a step-change in the pace, level of resource and intensity that HMRC will be devoting to investigating, challenging and resolving your tax affairs.’
The letters go on to say:
‘Where it becomes necessary to progress your tax affairs to litigation we will be looking at your actions and behaviours to see whether civil penalties should be charged.’
Typically the participants in receipt of these letters are usually wealthy individuals ordinarily dealt with by HMRC’s High Net Worth Unit (HNWU). The letters state the SAU will be working closely with the HNWU in a coordinated approach and seeking joint meetings with the participants involved.
The letters conclude with a warning:
‘If you do not settle now, or you decline to enter into discussions, I have instructed my staff to work with HNWU to take appropriate actions as rapidly as possible to progress all issues to resolution and to bring into charge all tax, interest and penalties at the earliest possible opportunity.’
This action is being taken before the serial avoiders special regime comes into effect next April. More information is available here
Author: Guy Smith, Tax Investigations Manager