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Innocent entanglements
Key points
- A UK resident but non-domiciled taxpayer purchases business properties.
- An offshore trust and company structure was standard tax planning for non-domiciliaries.
- The arrangements entered into gave rise to income tax disadvantages.
- Professional advisers omitted to mention the income tax charges.
- An HMRC enquiry asserted strongly that there had been a deliberate omission.
- The issue of unnecessary information notices under FA 2008 Sch 36.
- A successful review under TMA 1970 s 49A.
Taxpayers caught by reason of their innocent errors in the toils of an HMRC investigation often assume at first that their honesty and goodwill will protect them that HMRC will conduct its investigation with due regard to the evidence produced and that it will not make demands that are disproportionate to the culpability of their errors or to the tax at issue.
The first job of any adviser advising such clients is to disabuse them...
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