A landlord/property developer had received rental income and had purchased and sold a number of properties over a period in excess of twelve years. The full liabilities had not been returned to HM Revenue & Customs (HMRC)during the years Tax Returns had been submitted, and there had been a number of years when no Returns had been made.

HMRC opened an investigation as a result of publicly available information detailing property ownership, sales and rental payments.

The accountant who had prepared the Tax Returns was trying to deal with the HMRC investigation, but it was clear that he was making the position worse as he had neither the time nor the experience to deal with the mounting information requests and representation on behalf of his client.

The difficulties increased when the case was escalated from the Local Tax Office to the HMRC office dealing with cases of Suspected Serious Fraud and the Civil Investigation of Fraud (Code of Practice 9) procedures were applied.

The businessman was recommended to try Cobham Murphy and a representative of our Investigation Department discussed the position with him. It was explained that it was quite accepted practice for a Specialist Tax Advisor to be brought in to provide advice or representation at any stage of an Investigation.

Cobham Murphy engaged with the Investigator at HMRC, gathered the necessary information from the client and went on to prepare a thoroughly researched Report, in response to the challenge from HMRC. The data gathered and interpreted was used as a basis to commence negotiation with the Investigating Inspector.

A settlement was agreed in a much smaller sum that the property developer had originally feared and he was able to meet the liability without having to dispose of any of his properties to realise a large sum of capital. An unplanned sale which would probably have attracted an unwelcome tax bill.