1. Dealing with HMRC in 2012 (May Update) AVN Venus Tax LLP Chartered Institute of Taxation Leeds Branch

2. Background Some things that affect relations with HMRC  The way the Department is “organised”  HMRC’s array of Powers (incl: Schedule 36 FA08)  Penalty Regime  Compliance Checks  Working With Tax Agents “Consultation”  Litigation and Settlement Strategy  The evolving law on Discovery  Tax avoidance has a bad name  The Government needs money. Lots of it.

3. HMRC in 2012  Risk  Enquiries and Tax Avoidance  New IR35 initiative  Ever widening scope of HMRC’s powers  Schedule 36: Beckwith FTT decision  Schedule 36: ex parte hearings  Information requests becoming more aggressive

4. HMRC in 2012  Internal Review and ADR  HMRC’s attitude in litigation  Discovery  FTT: Charlton or Sanderson?  Court of Appeal: Lansdowne Partners  Where now with discovery?

5. HMRC in 2012 The Contractual Disclosure Facility Switzerland and the LDF Electricians Other initiatives (law of diminishing returns?) E-traders and auction sites http://www.hmrc.gov.uk/sa/record-keeping.htm http://www.hmrc.gov.uk/sa/rec-keep-self-emp.htm

6. Evidence As with so many tax matters, evidence and the burden of proof are crucial.  It has been said that “HMRC don’t let the small matter of a lack of evidence get in the way of a good investigation”  It has been said that “You get less time for manslaughter than some investigations take”

7. AVN Venus Tax LLP Contact us on 0845 226 2371 or 0844 811 1306 Andy Wells, 07778 159479 andy@avnvenustax.co.uk andy@avnvenustax.co.uk Paul Bradley, 07884 261517 paul@avnvenustax.co.uk paul@avnvenustax.co.uk Ryan Sample, 07794 871742 ryan@avnvenustax.co.uk