Our client was a non-UK resident individual whose tax affairs were subject to a COP8 enquiry initially raised by HMRC in 2019 into a payment which took place in 2007/2008.
The client had been assessed by HMRC in respect to a large amount of income (in excess of £500k) which he was clear he had not actually received. The assessment has also resulted in significant interest and penalties and the amount at stake was in excess of £250k. This understandably left our client feeling incredibly anxious particularly as the enquiry had been dragging on for some years.
We approached HMRC to suggest that they consider alternative dispute resolution (ADR) in order to bring matters to a conclusion. We find that this is often a much better option for clients as it avoids the need to attend tax tribunal or similar and often helps resolve disputes more quickly and cost-effectively.
During an ADR meeting held at our offices our client was able to verbally explain the situation and to address any areas of confusion. Whilst these had already been raise in correspondence with HMRC, dealing with them within the forum of ADR allowed HMRC to better understood the client’s position.
So much so that the ADR resulted in HMRC withdrawing all of their assessments on our client on the day of the ADR hearing – something which is incredibly rare as, even on occasions where assessments are withdrawn by HMRC, this is usually actioned several days or weeks later after HMRC have had time to reflect.
An amazing outcome for both our disputes team and the client!
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