Tax Health Plan (Amnesty for Medical Professionals)
Liechtenstein Disclosure Facility
Corporation Tax investigations
Disputes, Tribunals and Internal Review
These units comprise the residue of the former Special Compliance Office which was originally amalgamated from Enquiry Branch (fraud and prosecutions) and Special Office (avoidance); and then subsequently rebranded as Serious Civil Investigations when prosecution work was hived off to Revenue and Customs Prosecution Office. With Code of Practice 9 work also being hived off to the Civil Investigation of Fraud Units, Specialist Investigations now deals pretty much with large scale tax avoidance schemes and very large civil fraud cases where the minimum settlement is anticipated to be £500,000.
Tax avoidance schemes have become increasingly convoluted and provocative in recent years as tax loopholes have been closed off. Whilst it is very often the case that a scheme "works" in terms of the legislation, it is equally true to say that most schemes fail because they have not been implemented properly. If for example the paperwork in relation to a particular transactional step is not correctly drawn up or signed or whatever.
Enquiries of this kind have to be considered on a case by case basis. It is common for an element of the up-front scheme fees to be retained as a "fighting fund" in the expectation of a challenge from HM Revenue and Customs. Hector Hector will be happy to give you an independent assessment of your position if you have engaged in a tax planning arrangement which is being challenged by Special Investigations.