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A challenging environment – the new UK tax disputes regime

UK taxpayers and the professional advisers, fiduciaries and financial institutions that service them, including those in Switzerland, are having to come to terms with a harsh new environment, when it comes to tax compliance and the pursuit of tax liabilities and penalties by the UK tax authority.

HM Revenue & Customs (HMRC) is now making full use of a huge increase in information at its disposal: both from its own extensive information-gathering powers, and also the far more detailed information available to it via the Common Reporting Standard, data leaks and its super computer “Connect”. The UK government has also recently introduced a series of new rules which give HMRC the ability to impose much tougher penalties for non-compliance with UK tax obligations, even where such non-compliance is accidental rather than deliberate.

Drawing on the practical experiences of our tax and tax disputes teams in London and Switzerland and through use of case studies, we will look at a number of key issues coming out of the new regime:

  • Domicile enquiries: why are HMRC suddenly challenging more individuals’ non-UK domiciles even where they have become deemed UK domiciled under the 2017 legislation? What questions are HMRC asking and how should a client and their advisors respond?
  • How mistakes, from the simple to the highly complex, come about and how HMRC picks up on them with enquiries
  • Life after the Requirement to Correct: the new penalty regime from simple mistakes and unintentional failures through to outright concealed evasion and fraud
  • The impact of the General Anti-Abuse Rule (GAAR)
  • The risks for advisors, fiduciaries and financial institutions: penalties for enablers of defeated tax avoidance, DAC6 and the corporate offence of failure to prevent the facilitation of tax evasion

In a highly interactive panel discussion we aim to help advisors and their clients understand the new regime and how to respond when HMRC come knocking.


The Hotel Metropole, Quai du Général-Guisan 34, 1204 Geneva
9 April 2019 / 17:00 - 21:00

Stiftung Zum Glockenhaus, Sihlstrasse 33, 8001 Zürich 
10 April 2019 / 17:00 - 21:00

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