Been handed a tax investigation where HMRC keep referring to information he holds, I have my doubts that they do, as the details being stated are not correct and i would like to see where this information is from
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I would still give it a go. If you were at the first meeting then build on that, if you weren't then you can play the 'new kid on the block' card.
Much depends on how well you know your client, if you haven't done so already, give the client the first degree with dire warnings along the lines of "the games up chummy, they obviously know about the other properties, so you better come clean or you're going down for a long stretch". (OK maybe not quite like Inspector Reagan, but you get the picture).
Had one of these.
If you can't get the information from the client, tell the HMRC officer that you've no idea what he's talking about and he'll have to point you in the right direction.
The HMRC officer is then faced with a choice of disclosing his source or closing the case.
Fair play to him, though, for giving your client an opportunity to cough.
On the other hand, they don't always get it right.
Thanks, I have got the information from the client but it does not correspond with the information HMRC say they are holding, its as if they are fishing. The initial meeting notes were a bit creative !!,
Thanks, I have got the information from the client but it does not correspond with the information HMRC say they are holding, its as if they are fishing. The initial meeting notes were a bit creative !!,
Thanks, I have got the information from the client but it does not correspond with the information HMRC say they are holding, its as if they are fishing. The initial meeting notes were a bit creative !!,
The principle's the same. Tell the officer you don't agree and refuse to discuss it further until he reveals his source. Only then will you have an opportunity to dispute their information.
It is a property portfolio case, they keep saying they hold information of properties sold which the client says he does not own (so he says), details from letting agencies regarding properties the client says he does not own and has copies of lease agreements which give different terms to the leases held by the clients solicitor
Sounds like the client is either (a) lying
(b) got a similar name to someone else
(c) tried to be clever but its backfiring.
Id grill the client really hard and explore why the inspector may think what he does, to see if there are explanations.
The inspector is trying to flush out as much as they can, so wont reveal all incase they know about (say) 4 and there are 6. But if there are multiple properties, see if they will give a strong hint. Eg which town or area on one of them. Should be enough to get the client to fess up if they are lying.
I have asked the client these questions as I do not want anything to come back to me, he is adamant he is 'clean', I will respond carefully and then arrange a meeting
It is a property portfolio case, they keep saying they hold information of properties sold which the client says he does not own (so he says), details from letting agencies regarding properties the client says he does not own and has copies of lease agreements which give different terms to the leases held by the clients solicitor
Should be easy to settle one way or the other.
I suggest the best way is to call the Inspector and state that the client wants to make a FOI Request. Ask him his advice whether to do this through the formal channels, or whether he will simply provide it to you to save time.
When a company goes insolvent, the Director can make a FOI request on the information provided to the Insolvency Service, on which they based their enquiry. I don't see why this is any different.
Had some of these in the past.
Identified issue that client was a Trustee & Trust had sold properties.
Once addresses identified simple to refer Inspector to the Trust tax returns & case quickly closed.
Obtain the addresses of the properties in dispute & carry out some Land Registry searches.
