Representatives from the NI Tax Committee met recently with the head of HMRC’s East Kilbride Wealthy team. This unit deals with most NI taxpayers within the remit of the Wealthy team which comprises the wealthiest taxpayers in the UK (net worth of £20 million or more).

Matters of common interest were discussed and the Committee is examining proposals to engage with this team going forward for the benefit of members. Key messages from the meeting were as follows:-

• In the context of accelerated payment notices and follower notices, HMRC are mainly dealing with a number of old legacy cases, including disguised remuneration schemes and employee benefit trusts. More follower notices will be issued as cases progress through the Courts.
• If a client is within the remit of HMRC’s Wealthy Unit and they have an unresolved accelerated payment notice, contact should be made early with the relevant Wealthy customer relationship manager (“CRM”).
• HMRC are encouraging their own teams to engage with taxpayers and agents to resolve matters and explore opportunities to close open enquiries. This can include a discussion on sensible payment arrangements, if required.
• Early and open dialogue with the relevant CRM is advised in the context of any disclosure or matter a taxpayer wishes to resolve.
• In the context of information exchange arrangements, HMRC are receiving fairly basic information which often requires further explanation/clarification from the taxpayer and/or their agent. The reasons for an individual being linked to an offshore account can be wide and varied and thus it cannot be assumed, without additional information/explanation being sought that they have been involved in evasion or avoidance activity. HMRC may therefore need to seek explanations from taxpayers and their agents in respect of offshore information received.