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Tax Controversy Risk Management - Ernst & Young - United Kingdom

Tax Controversy Risk Management (Tax Investigations)

Ernst & Young’s Tax Controversy Risk Management (TCRM) team specialise in the management and resolution of contentious issues and disputes with tax authorities both in the UK and worldwide.

The team is headed by Chris Oates and team members include individuals who have worked in Special Investigations, Large Business Service, Anti-Avoidance Group and Local Compliance within HM Revenue & Customs. We therefore have an unparalleled insight into the world of tax risk and dispute resolution. The team has a proven track record of steering clients through difficult enquiries and complex negotiations to reach successful outcomes.

In addition to assisting with all types of HMRC investigations, we also conduct health checks to ensure that your systems and procedures are robust enough to withstand HMRC scrutiny, should you be selected for enquiry. For more detail on how we can help you, please see our “What we do” pages.

If you or your company is subject to an enquiry, or you are interested in ensuring that your systems and procedures are robust enough to withstand HMRC scrutiny, please contact Contact Us Chris Oates on +44 [0]20 7951 3318, or call our 24 hour helpline on 0800 917 4122, for a free preliminary discussion of how Ernst & Young can help you.

Laerstate: Company residence update

HMRC's recent success in the Laerstate BV case has received a lot of publicity, particularly since, in recent years, it has enjoyed limited success in company residence cases. However, here HMRC successfully argued that a Netherlands incorporated company was UK resident, despite Board meetings having been held, and various resolutions and other documentation also having apparently been signed, outside the UK. Read our update pdf 285K, October 2009

The Liechtenstein Disclosure Facility (LDF)

On 11 August 2009 HMRC announced the signing of two ground breaking tax agreements with Liechtenstein. The aim of these agreements is to ensure offshore investments in Liechtenstein made by UK residents are properly taxed and represent a commitment by Liechtenstein to increase its tax transparency. Find out more.

New Disclosure Opportunity (new tax ‘amnesty’)

HMRC have released further details of the ‘New Disclosure Opportunity’ (NDO) (the new “tax amnesty”) that was announced by the Chancellor in the 2009 budget.  A formal announcement by HMRC, accompanied by a publicity campaign, is expected to be made shortly. Find out more.

The tipping point: Where tax risk and internal audit meet

Effective teaming between tax and internal audit could be the way forward in helping to manage tax risks across the enterprise pdf 229K

Improving taxpayer accounting systems: holding senior officers personally liable

The introduction of personal liability upon senior accounting officers within large corporates has set pulses racing and it has certainly begged the question; who on earth would sign up for this job? Find out more.

HMRC to ‘name and shame’ tax evaders

At present HMRC generally conducts their review of the affairs of taxpayers in a confidential manner, but this is all set to change. Find out more.

Enquiry management and resolution

To find out more about reducing the impact of tax enquiries and investigations, download our brochure pdf 88K

News

Contacts

For more information, and to find out how we can help, contact our 24 hour helpline: 0800 917 4122, or contact one of our Tax Risk specialists.

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