We acted for a client who had been served with both a follower notice (FN) and an accelerated payment notice (APN) in relation to a failed tax planning scheme involving a gilt strip. HMRC had determined that the scheme did not work and opened an investigation into the client’s connected company. We made detailed, persuasive representations in response to the FN and APN which led to HMRC withdrawing both of them. Following the representations, HMRC also made amendments to the client’s Self-Assessment return which actually resulted in a tax refund.
Our expertise and understanding of HMRC processes enabled us to:
successfully argue that the process by which HMRC investigated the client’s connected company and then raised the notices was ultra vires;
spot that HMRC’s calculations of the amount of the tax liability were incorrect; and
make representations that HMRC best practices were not followed in the issuance of the notices.
This combination of factors enabled the client to avoid a huge tax bill and receive a refund.
On 6 April 2021 Practice Direction 57AC (PD57AC) came into force which radically affects the way in which trial witness statements must be prepared in the Business and Property Courts (BPC). The BPC is the forum for a wide range of disputes including Commercial, Competition, Business, Admiralty, Technology, Intellectual Property, Real Property, Probate, Insolvency and Company cases. Typically, cases in the BPC are document heavy and as such the scope for witnesses to provide useful and relevant evidence of fact is arguably limited.
Lola Poyner, aged 6, from Warwick has already raised more than £2,000 for Warwick Hospital and University Hospital Coventry and has now received her biggest single donation yet with a further £175 from Leamington based solicitors, Wright Hassall.