If HMRC has opened an enquiry then they are looking into your affairs and will contact you to gain further information. It is important to know that anything provided from this point on could be used in evidence against you. It is imperative that you receive professional advice and guidance at this point.
If the enquiry is from Specialist Investigations or HM Revenue & Customs are offering the Contractual Disclosure Facility then you need specialist advice.
If HMRC can demonstrate that you have acted deliberately to evade tax or have failed to tell them about a liability they can recover the tax over the last 20 years. If it can be shown that you only acted carelessly then HMRC can only recover tax for the last 6 years.
This is where the knowledge of Pathfinder comes into play, we know what information HMRC needs to have to minimise the overall liability and avoid HMRC raising incorrect assessments. It is easier to stop the assessments being issued than deal with the appeal process.
HMRC can ask for any information that they want. The expertise from Pathfinder is in agreeing with HMRC what information they are entitled to and what is going to be supplied. These are often three completely different answers.
You may be invited to a meeting with HMRC, or often they will invite themselves to a meeting at your business premises. Despite their enthusiasm for such visits or meetings in reality HM Revenue & Customs have, in most cases, very limited rights to insist upon a meeting or a site visit.
Our experience is that taxpayers we attend meetings with HMRC whilst unrepresented often end up with difficult enquiries. Even meetings where taxpayers are properly represented require careful thought and need to be tightly controlled to ensure that matters do not spiral out of control.
Each tax enquiry is different and so no timescale can be sensibly provided without looking into your circumstances to establish the size and complexity of the case. However we would normally expect most enquires to be substantially complete within a year, more complex ones would naturally take longer.
Firstly do not panic, do not ignore them, and do not pay them.
If you have a tax adviser speak to them immediately. If you are still unsure of the position, or you and your advisor need help, seek advice from Pathfinder.
An APN requires you to pay the tax upfront and then argue about the liability. Certain conditions need to be met, but you will need to pay first and argue later. If you were not expecting an Accelerated Payment Notice or cannot pay, then seek advice.
You should consult an experienced tax dispute adviser who will be able to explain it to you. Even at that late stage approaches to HMRC and negotiations can result in significant reductions in liabilities.
Get the right people to do the job. At Pathfinder, we have the necessary experience and expertise to handle such negotiations on your behalf.