HMRC arrears

One80 advisers successfully negotiated a payment plan with HMRC following multiple accelerated payment notices.

The challenge

As a result of multiple participations in tax avoidance schemes, a skilled professional was faced with multiple accelerated payment notices (APNs) as well as liabilities from non-DOTAS registered schemes. As the client became more concerned about his financial position he contacted his accountant who subsequently made the introduction to our One80 experts.

The solution

Understanding the urgency of the situation, our One80 specialists undertook an immediate review of our client’s financial position. We ensured that we considered both their assets and liabilities as well as their income and expenditure to give a full picture of the matter at hand.

Following the conclusion of our review it was clear that our client had limited unencumbered assets and therefore would not be able to absolve himself through paying off debts alone. With limited liquidity it was apparent that a five plus year time to pay arrangement in addition to asset realisations would be required to extinguish the historic liabilities. Furthermore, it would be necessary to engage with HMRC to seek and agree the basis of calculation and total liability.

We subsequently engaged in a negotiation process whereby it was firstly necessary to initiate correspondence with HMRC and develop a strategy which was compromisable between both parties. In order for HMRC to agree we needed to orchestrate a proposal which showed that the arrangement would result in them eventually receiving a full payment.

In comparison to our clients estimated tax liabilities, a repayment strategy was structured which involved the refinance and orderly sale of certain assets. We were successful in obtaining HMRCs approval and it was agreed that the actions should commence to ensure the best possible positon when the settlement terms were forthcoming.

One80 advisers successfully negotiated a payment plan with HMRC following multiple accelerated payment notices.

In comparison to our clients estimated tax liabilities, a repayment strategy was structured which involved the refinance and orderly sale of certain assets.

The outcome

Following the refinancing of certain assets, payments were made to extinguish the APN liabilities and funds paid on account to mitigate the risk of further penalties and application of interest. Information requests by HMRC were facilitated and confirmed liabilities were met with funds paid on account where available. Following receipt of complete calculations, time to pay was agreed for a four year period to meet the tax avoidance liabilities in full.