Success Stories

Our client had restructured their business and claimed Entrepreneurial Relief (ER )on the adviceof their accountant. ER is now known as Business Asset Disposal Relief. This relief reduces thecapital gains tax at 10%

HMRC opened a compliance check into the properties worth over £2 million that weretransferred into the new company. During thistime our client was running two care homes and you can imagine what they were going through during the covid pandemic

HMRC believed that the property transactions were all part of a scheme whose principal aimwas to avoid/minimise tax rather than for a genuine commercial purpose and the “Targetted Anti-Avoidance Rule”, therefore ER would be disallowed. This resulted in a £352,035.54 tax bill

We defeated HMRC’s argument. In this case, HMRC sent an email thanking me for handlingthe case professionally. We don’t need to be adversarial to win a case against HMRC.

Our client had restructured their business and claimed Entrepreneurial Relief (ER )on the adviceof their accountant. ER is now known as Business Asset Disposal Relief. This relief reduces thecapital gains tax at 10%

HMRC opened a compliance check into the properties worth over £2 million that weretransferred into the new company. During thistime our client was running two care homes and you can imagine what they were going through during the covid pandemic

HMRC believed that the property transactions were all part of a scheme whose principal aimwas to avoid/minimise tax rather than for a genuine commercial purpose and the “Targetted Anti-Avoidance Rule”, therefore ER would be disallowed. This resulted in a £352,035.54 tax bill

We defeated HMRC’s argument. In this case, HMRC sent an email thanking me for handlingthe case professionally. We don’t need to be adversarial to win a case against HMRC.

Already one tax investigation expert had represented this client hence our client stated he would be happy with even 10% reduction in his personal tax liability.

The CT PLN was reduced from £117,805.61 to £28,417.39. A saving of £89,388.23 which is a 76% reduction in his personal tax liability.

We established that the directors loan account was not overdrawn on this case.

There was considerable resistance from this HMRC caseworker. We had to request the caseworker to seek further technical advice as we had reached an impasse with the caseworker. This is an example of how you can disagree with the caseworker, but still work collaboratively and reach a resolution on the case. The caseworker then sought technical advice from an HMRC tribunal caseworker and senior manager, who agreed with our technical approach on the tax position. Fortunately, we reached a settlement without the need to go to ADR.