Tax Dispute Resolution

Some times, no matter how considerable the experience of the accountant or solicitor acting for their taxpayer client, a dispute arises with HMRC where outside input is sought.

It may be simply that correspondence with HMRC following receipt of an Enquiry Notice seems never-ending and no room for agreement seems likely. Alternatively, it may be that immediately following receipt of the Enquiry Notice it became apparent that serious differences in approach existed and that technical issues being raised by HMRC need careful handling..

It is in these and other situations that professional advisers turn to Slevin Associates.

Slevin Associates' role varies according to the particular circumstances of the case in question and the requirements of the client. Sometimes we keep 'behind the scenes' by limiting our activities to simply draft letters for the taxpayer's professional adviser to send to HMRC. In other situations, it may be considered best if we deal directly with the Tax Inspector for the duration of the enquiry.

We always hope to be in a position to bring the matter to a conclusion after carrying out a careful analysis of the situation, i.e. analysis of both the facts and the tax legislation relevant thereto.

As with our tax planning assignments, it is essential we have a firm understanding of the full facts before trying to advise on the best course of action. Once in possession of the full facts we can then agree how the parties involved should proceed as regards satisfying the Tax Inspector's lawful demands for information, contradicting technical arguments he/she has put forward or, as may be required, negotiating conclure of the matter if the Inspector is found by us to be right!

Some disputes can only be resolved by taking the matter to the independent tribunal known as the Special Commissioners. Here Slevin Associates can assist in presenting the taxpayer's case and/or briefing Tax Counsel to take the matter forward. Tax Inspector's seldom relish the idea of the case they are handling being taken to an independent tribunal. This reluctance on the part of Inspectors can work to the taxpayer's advantage in cases where the arguments are borderline.