Our People

GARY ROWSON
Tax Director

  • Instructed by solicitors acting for Executors of an Estate who had knowingly not declared assets of the Estate (which had been transferred to them personally).  In subsequent years, they compounded matters by knowingly omitting income/gains they had personally received from the undeclared assets.
    • Successful resolution on a civil basis with full penalty mitigation.
  • Specialist advice on issues identified as part of a routine HMRC Compliance Check.  The client had sought to protect his world-wide asset position by transferring ownership into a complex offshore structure.  Significant levels of income had not been returned in the UK.
    • Significant risk of prosecution by HMRC or, if the case continued on a civil basis, then the potential financial penalties were huge.
    • Successfully argued for ‘careless’ errors, which limited both the period of assessment and the penalties charged.
  • Acted for a High Net Worth Individual who had previously set up an offshore settlement into which income and a right to income had been transferred.  Previously unforeseen errors relating to this structure were identified as part of divorce proceedings.  Significant levels of income had not been returned in the UK.
    • Serious reputational issues could have been faced by this high profile client.  Settlement secured via a voluntary disclosure to HMRC and the case being worked under COP8 (i.e. no allegation of fraud or dishonesty).
  • Specialist advice to a non-UK domiciled High Net Worth Individual.  HMRC’s Large & Complex Office had commenced a wide-ranging ‘dual contracts’ enquiry.
    • Factual disclosure presented to HMRC, including detailed evidence required to support the client’s case.  A number of complex technical tax, PAYE and NIC issues were also successfully argued.
  • Instructed by a High Net Worth Individual who was being criminally investigated by a regulatory authority for suspected non-tax offences.  His UK tax affairs were incorrect such that there was also the serious risk of prosecution by HMRC.
    • If the case had been dealt with under COP9 then an explicit admission of deliberate conduct would have been required to protect the client from a HMRC criminal investigation.  Such an admission could have adversely impacted upon the other proceedings.
    • Despite the ongoing regulatory investigation, we successfully argued that the client could register for the Liechtenstein Disclosure Facility (LDF).  The terms secured under the LDF were such that tax and interest for ten years of assessment were effectively reduced to NIL and a 10% penalty was secured.