Financial Skills: Tax: Risk Management in Tax - From Disclosure to Litigation

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About this class

The course considers those areas of tax law where what is the correct tax treatment can be a matter for judgement. HMRC's approach to such cases is examined. How advisers can best represent their clients' interests (and minimise the chance of any potential negligence actions) is discussed as is the impact of Self Assessment and the Human Rights Act onHMRC powers and practice. Finally, the usefulness of litigation in resolving contentious areas is considered.

Contents of this class

PRACTICE PROTECTION AND DANGERS AREAS

• How 'technically correct' advice can leave a practice open to a negligence claim
• Case study based on a recent High Court decision
• Individual residence, domicile and remittances
• Corporate residence versus transfer pricing

NEW TAX PLANNING DISCLOSURE REQUIREMENTS

• Regulatory overview
• Problems
• Consequences

TAX AVOIDANCE AND TAX EVASION

• Legitimate and illegitimate avoidance
• Evasion -voluntary disclosure, Hansard statement, prison
• Questions of motive, intention and belief
• General Anti Avoidance Rule (GAAR) and Para 13, Sch 9, FA 96

HOW HMRC CAN LOOK INTO YOUR HEAD

• Access to a taxpayer's 'documents'
• Access to a taxpayer's 'particulars'
• Access to other people's documents
• Access to professional advice
• Defences -relevance, proportionality and privilege
• Statutory restrictions -Human Rights Act, Data Protection Act

HOW HMRC CAN LOOK INTO YOUR HOUSE

• Dawn raids
• Warrants

IMPLICATIONS OF SELF ASSESSMENT

• Penalties
• Discovery assessments

IMPLICATIONS OF HUMAN RIGHTS ACT

• Investigations
• Penalties

DEFENSIVE AND AGGRESSIVE LITIGATION

• Cost/benefit analysis
• Relationship with HMRC
• Litigation strategies

Financial Skills: Tax: Risk Management in Tax - From Disclosure to Litigation / CM9822

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