Mitigating and Managing HMRC Investigations for HNW Private Clients

Helen is a Partner in the Joseph Hage Aaronson contentious tax team specialising in UK and international tax disputes. She is a Solicitor and Chartered Tax Adviser, a member of the Society of Tax and Estate Practitioners and is a CEDR accredited mediator. She has recently been included in the City Wealth Leaders List Top 100 Private Client lawyers, is included in the Private Client Global Elite Directory 2023 and appears the Tatler Address Book 2023. Helen writes prolifically for numerous tax publications and is an active committee member at the Chartered Institute of Tax and the Worshipful Company of Tax Advisers.

Helen advises both individuals and corporates either engaged directly or as a consultant to an extensive network of professional firms and financial institutions who repeatedly call upon her expertise.

Helen has successfully run numerous residence and domicile cases but will also turn her hand to a wide variety of contentious and advisory tax matters. Helen is an industry leading specialist at running highly technical COP9 investigations where she has a proven track record of successfully negotiating very favourable settlements.

Ravinder is a barrister who specialises in substantial commercial disputes in litigation, arbitration and mediation. He has recent experience of banking and finance, civil fraud, company, construction and insurance disputes in the United Kingdom, Middle East and India. Ravinder also has experience as a criminal prosecutor and has represented individuals and businesses charged with bribery, corruption, fraud and regulatory offences.

Ravinder has acted in cases at all levels of the English civil and criminal courts and in arbitration under several different rules including ICC, LCIA, DIFC-LCIA and LMAA.

During his HMRC career, Kevin has undertaken a range of technical, operational and compliance roles as well as programme management within HR and HMRC Communications. Kevin has managed relationships with some of the UK’s largest businesses, headed-up HMRC’s Incentives and Relief compliance operations and led technical and tactical teams in a range of personal tax environments. Kevin became the Deputy Director of Wealthy in September 2022.

Outside of work Kevin is a qualified Basketball England Coach and has coached players from 7-18 from local to National Team Development Programme level.

Jonathon joined HMRC in 2013 as a case director in the ‘Affluent’ unit where he managed investigations covering a range of complex matters. He has subsequently been a Wealthy Compliance Lead where he led HMRC’s compliance activities into some of the wealthiest individuals in the UK. He is now the Assistant Director for Wealthy National Operations where he leads specialist teams focusing on complex personal tax matters including the High Risk Wealth Programme.

Prior to joining HMRC, Jonathon worked in practice for seven years where he predominately advised owner-managed businesses across the North East. He is a chartered accountant, chartered tax adviser and holds a master’s degree in Taxation and Fiscal Policy.

Heading up RPC's Tax Disputes offering, Adam Craggs has over 30 years' experience in the contentious tax and white collar crime field.

An accredited mediator, Adam advises on a wide range of contentious tax issues (direct and indirect taxes), including HMRC enquiries and litigation before the Tax Tribunals/ Higher Courts, and white collar crime investigations. 

During his career, he spent 16 years in the Solicitor's Office at HMRC, where he provided legal advice on a large number of high-profile civil and criminal cases.

Adam is the co-author of Tolley's 'A Practical Guide to Tax Appeals' and a contributor to 'Whiteman & Sherry on Income Tax' and 'Whiteman & Sherry on Capital Gains Tax'. He is also the author of a number of guidance notes written for Tolley's 'Online Guidance' and the author of two practice notes written for PLC on alternative dispute resolution in tax disputes and criminal prosecutions for tax fraud.

Adam writes and lectures widely on tax matters and is a regular contributor to RPC's Tax blog, Tax Take.

Dawn manages voluntary disclosures and resolves complex tax investigations. She also uses mediation to resolve disputes with HM Revenue & Customs. Dawn specialises in UK personal tax and cross border issues. Her recent work has focused on changes in HMRC powers, information exchange and data gathering. Dawn is a recognised expert on tax disclosures and is a regular presenter and writer. Dawn regularly contributes to articles and news stories from tackling tax avoidance to the tax implications of budget announcements. In September 2018, Dawn was announced as New Partner of the Year at the British Accountancy Awards.

Morag is a Barrister and Partner in the Tax team, specialising in litigation and the settlement of disputes.

She is experienced in helping clients find bespoke legal solutions to the most complex tax problems, and acts for clients from all over the world – including household names in sport, film and TV; international families; and other prominent individuals.

Prior to entering private practice, Morag spent time at the independent Bar, the Big Four and in-house at an investment management firm. Her deep understanding of tax and litigation procedure, coupled with her extensive experience in advising on the lawfulness of HMRC’s decisions ensures that she is able to develop strategic solutions that both assist and protect clients.

Morag offers a wide range of private client litigation and contentious tax services ranging from tribunal litigation and complex tax investigations, to cases of suspected fraud, settlement of marketed tax avoidance schemes, conduct/fairness proceedings against HMRC, and claims where incorrect tax advice has been given.

She is known for her inter-disciplinary approach to tax, which often includes working with other experts and specialists, leveraging insights from different areas of law – securing good outcomes for clients both in and out of the courtroom.

In addition to contentious work, Morag is also able to advise clients on their business interests and any possible tax risks when structuring their affairs around the world and regularly advises on the tax consequences of living or working abroad, the purchase and movement of luxury assets, and the tax implications of divorce for international couples.

Alex is a founding partner in 2001 of Hughes Fowler Carruthers, the top tier niche family law practice. Alex specialises in English family law, complex divorce, and financial work and children’s work, in particular international cases. His clients are high net worth individuals with complex legal issues including trusts and jurisdictional disputes, Alex in featured in Spears’ Family Law Index’s ‘Top Recommended Family Lawyers’ list and is also listed in Tatler Address Book’s advisory as one of the leading family lawyers in their trusted network of influential and elite private client experts with “gilt-edged” expertise. He regularly lectures on the interface between divorce and trusts. He is highly recommended by peer review publications and has been involved in a number of high profile and ground-breaking legal cases. Alex has been a regular in Chambers’ band 1 for many years. Chambers UK 2023 quotes a contributor as stating that "He is sharp, incisive and astute; he is tactically brilliant and extremely patient.".

Hugh specialises in tax disputes and investigations. His clients include internationally mobile high net worth clients and other private individuals, family businesses, trustees, entrepreneurs and corporates, both small and large. His practice covers the full range of UK taxes, both direct and indirect; including income tax, CGT, inheritance tax, SDLT, corporation tax and VAT.

Hugh has experience of litigating tax cases at all levels, from the specialist tax tribunals through to the Court of Appeal and the Supreme Court. A significant element of Hugh’s practice involves remedying unsuccessful planning (often involving complex trust arrangements), including by way of claims for mistake and rectification in both the UK and offshore jurisdictions. He also acts on tax-related professional negligence disputes and other trust and commercial disputes with a tax angle.

Hugh has been recognised as a 'Rising Leader' in Legal Week’s Private Client Global Elite 2022.

James has a wide ranging practice, advising on UK and international taxation, residency and domicile, offshore pensions and trusts, asset protection, succession planning and HMRC disputes. He was also a finalist for 'solicitor of the year' in the Law Society Excellence Awards 2018. He is ranked by Spears as being in the Top 10 tax and trust lawyers in the UK.

The Legal 500 describes him as a “very experienced tax lawyer with commendable professionalism and responsiveness ” and Chambers describes James as "the fount of all knowledge". He has a wide ranging practice, advising on international trusts, taxation, pensions and HMRC disputes.

James is currently named in the eprivateclient's "50 Most Influential in Private Wealth" and his team is the holder of various awards, including "International Law Firm of the Year” in the prestigious STEP Private Client Awards (2018), "Private Client Law Firm of the Year" in the Wealth Briefing Awards (2015, 2017 and 2018) and the British Legal Awards (2015). James is one of the most prominent private client lawyers in the UK and frequently appears in the press and broadcast media (Sky News, BBC TV News, BBC Radios 2 / 3 / 4 / 5, Bloomberg TV and the BBC World Service).

As well as being a solicitor, regulated by the SRA, he is a Registered Tax Technician, regulated by the Association of Tax Technicians (ATT). He is an active member of STEP and a contributing editor for Lexis/Nexis.

Dominic is the head of Tax Dispute Resolution at Evelyn Partners. He has over 30 years’ experience of contentious tax matters and specialises in helping individuals and businesses navigate complex issues with HMRC. Before moving into practice in 2007, Dominic spent 18 years with HMRC in a variety of investigation and tax compliance roles.

Dominic’s team also helps clients make voluntary disclosures to HMRC under various programmes such as the Contractual Disclosure Facility (COP9) and the Worldwide Disclosure Facility (WDF).

Dominic has also acted as an expert witness in a number of civil proceedings, including those relating to professional negligence claims against tax advisers.

David leads the tax disputes and investigations team in the Midlands and uses the knowledge and skills gained from over 14 years of tax dispute work (8 as an Inspector of Taxes) to manage a wide range of clients with their interaction with HM Revenue and Customs. These clients range from large multinationals, owner managed businesses to sole traders. Each client may be facing differing challenges, be it through accusations of tax fraud, through the use of tax avoidance schemes or through the simple misunderstanding of the complex rules. However they all have the same aim when they chose Grant Thornton to assist; to resolve the issue in a cost effective and timely manner, allowing them to concentrate and focus on their commercial activities.

Grant Thornton achieves this through the collective use of our experienced and knowledgeable team, which consists of former tax inspectors and highly tax qualified individuals (CTA and STEP amongst others).  That collective experience and knowledge truly provides exceptional results for our clients. 

Whilst David successfully negotiates solutions for clients across a wide range of taxes, his speciality is in resolving long and drawn out tax avoidance enquiries. Having spent part of his career in HMRC’s Counter Avoidance team he understands HMRC’s settlement strategies amongst a wide range of schemes and apply that knowledge to clients fact patterns.

Outside of work he loves all sports. His days of participating in any competitive sport are over, so he gets his fix through coaching and also refereeing football. This is in and around the time that is dedicated for being a personal chauffeur to his three sport loving children.

Dion has nearly 20 years of experience in tax, most of which has been performing a variety of roles at HMRC from VAT to COP9 investigations to policy lead for cryptoassets. He is now part of the crypto team at Andersen where his knowledge on taxation is highly prized and provides a unique perspective.  His experience brings unparalleled in-depth knowledge on cryptoassets and their impact on direct and indirect taxation for individuals and businesses.

Oliver has a practice encompassing all areas of tax law, contentious and non-contentious.

“Oliver Marre is “our go-to when we need advice,” reveals an instructing solicitor, adding: “He’s extremely approachable, knowledgeable and brilliant with clients.  Marre often advises high net worth clients on a range of tax matters.  Another interviewee enthuses: “What sets him apart, I think, is his ability to relate to clients and explain difficult concepts or strategic points to them.  I am always confident in recommending him to clients and colleagues.”  (Chambers High Net Worth)

Oliver is also listed in the other main legal directories.  Who’s Who Legal refers to his “strategic prowess”.

As well as his broad general revenue advisory work and litigation, Oliver provides tax advice in the contexts of trusts disputes, mediations, in cases before the Family Division (including complex or HNW divorce cases) and in relation to the taxation of charities and charitable donors.

Ben acts for clients from a wide range of industry sectors, including large multinationals, owner-managed businesses and high-net worth individuals. Chambers and Partners (2022) describes him as “a rising star” and a “fluent litigator”. He is also recommended as “extremely easy to engage with, very hard-working, understands the technical issues of tax law that arise” and “someone who provides clear advice”.

Ben has a wealth of litigation and advisory experience, including appearing in cases before the Court of Appeal, Supreme Court and Court of Justice of the European Union in tax appeals and claims for judicial review which concern corporate, private client and indirect tax issues. Ben also acts and advises in commercial and chancery proceedings with tax aspects, including cases concerning professional negligence, trusts, partnerships, insolvency, family law, and property conveyancing. He also acts and advises in cases concerning other charges, such as business rates and Community Infrastructure Levy.

Ben lectures and writes on a variety of subjects, and has particular specialism in relation to the taxation of cryptoassets and other digital assets. He is the author of the tax chapters in Sport: Law and Practice (Lewis and Taylor, 4th ed) and a contributor to Hamilton on Tax Appeals.

Sophie advises some of the firm’s largest family clients regarding their wealth structuring, succession planning and trusts. Her focus is primarily on UK resident and/or domiciled individuals, trustees and beneficiaries, with a particular interest in cross-border taxation and succession issues affecting UK expats in France and Malta.

She also have experience providing tax and trust advice in the context of matrimonial disputes and pre-nuptial agreements.

In addition to the firm’s own Foundation, Sophie has established and registered a number of charitable trusts and companies for clients while also being a member of STEP (the Society of Trust and Estate Practitioners).

Sophie has been listed as a Rising Leader in the Private Client Global Elite Directory 2023 which is a list of the world’s elite lawyers advising UHNW clients nominated by peers amd was awarded the Gold award for “Lawyer of the Year – Partner” in the Citywealth Future Leaders Awards 2021 and the Silver award for “Lawyer of the Year – Partner” in the Citywealth Future Leaders Awards 2019. She was also selected as one of the 2019 Citywealth Future Leaders Top 100: Super Advisors and one of the 2017 Citywealth Future Leaders Top 100.

She has been recommended in the Legal 500 2019 editorial with the comment: “very strong and capable of handling delicate matters for demanding UHNW clients” and was also named as one of eprivateclient’s Top 35 Under 35 in 2014.

Waqar is a Partner in the Dispute Resolution department, focusing on the resolution of complex tax matters. He acts for high net worth individuals and corporate clients across all sectors in respect of HMRC disputes and investigations across the full range of taxes. This typically includes VAT disputes, employment tax matters (including 'IR35'/off-payroll working), customs/excise duty issues, tax fraud investigations, and more recently, National Minimum Wage enquiries.

Waqar is known for his commercial approach to matters involving HMRC and has a strong track record of helping clients settle without the need for a court or tribunal hearing, particularly through the effective use of Alternative Dispute Resolution (i.e. mediation) with HMRC. He also has considerable experience in judicial reviews and group litigation orders and has led high profile matters at all levels from the Tax Tribunal through to the Supreme Court (including referrals to the Court of Justice of the European Union).

Waqar has been regularly recognised in both Legal 500 and Chambers & Partners as 'one to watch' and a 'rising star'. He was listed in AccountancyAge's '35 under 35' in 2019 and regularly contributes to Tax Journal, Taxation, and other similar publications. Waqar is also the annual webinar presenter of the key tax cases of the year for Lexis and an active member of the VAT Practitioners Group. Waqar is a qualified member of the Association of Tax Technicians (ATT).

Pete is head of the firm’s Sports & Entertainment Group and advises a range of corporate and individual clients, primarily in the sports and entertainment sector.

His major clients include both international and national governing bodies of sport, clubs, major venues, rights holders, other sports businesses and individuals. Pete now advises over 70 Premier League footballers on all aspects of their tax affairs.

He also provides tax advice to companies and individuals across the wider entertainment sector, including film, television, music and e-sports.

In addition, Pete also has a strong client base in the entrepreneurial and owner-managed business space, focusing on providing commercially driven tax-efficient solutions in this sector.

Pete spent over 10 years at Deloitte, initially as a general corporate tax specialist in Manchester before moving to London in 2005 to lead the tax side of Deloitte’s Sports Business Group, moving to Saffery Champness in 2011. In 2012 Pete was listed in the Accountancy Age Top 35 under 35, and in 2015 was voted into Taxation Magazine’s Top 40 under 40.

Pete regularly speaks at industry conferences about the key taxation issues in sport, as well as appearing in all forms of media. He is well known as a trusted adviser to major stakeholders across the sports industry.

I am a Client Services Director in the Jersey office.  Having qualified as a non-practising Barrister and Solicitor of England and Wales I spent five years in private practice in both England and Jersey.

Thereafter I moved into the offshore finance industry in 2009, completing the STEP diploma in International Offshore Administration.  My legal background enables me to specialise in the administration of contentious, complex and / or distressed offshore structures, in particular those involved in litigation or under criminal or tax investigation. 

Jenny is a media and communications consultant with more than 20 years’ experience. As a former TV correspondent, Jenny worked for BBC World, ITV News, Channel 4 News and NBC. Jenny has reported live from multiple locations around the world, covering everything from breaking news to geopolitics.  She has lived and worked in the UK, the US and South America.

In Washington DC, Jenny was a Press Advisor to the British Ambassador to the United States and Chief Communications Officer for Military and Defence, where she briefed senior politicians and top generals ahead of media interviews. As a trusted media handler, Jenny has accompanied the UK Defence Secretary and Foreign Secretary to the White House and the Pentagon.  Jenny also worked in International Public Affairs at Edelman Global Advisory, developing and executing global communications strategies for government and corporate clients. 

Highly skilled at writing speeches and opinion editorials for senior leaders, Jenny has run numerous press conferences, written news articles and successfully pitched countless stories to journalists. Jenny has also worked as a communications consultant, media trainer and film producer, advising C-Suite Executives from global corporations and INGOs, and has a degree in Law (LLB) from the University of Exeter.

Helen is a highly experienced media litigator who has specialised in this field since 2002. She has acted for claimants and defendants in high profile defamation, privacy and harassment cases including obtaining and resisting injunctions.

Helen has provided pre and post publication advice to a broad range of clients including celebrities, politicians, companies, pressure groups, regulators, newspapers and publishers. She also provides advice on intellectual property, data protection and contempt. She joined Kingsley Napley in June 2016 from David Price Solicitors & Advocates.

Stuart Wakeling is a Managing Partner at Henley & Partners and the Head of the firm’s London and Nigeria office. Stuart has almost 10 years of experience in the investment migration industry, which is based on his 13 successful years in private banking at Coutts and HSBC.

Stuart has 19 years’ relevant experience in advising high- and ultra-high-net-worth individuals, identifying and managing risks, and seeking out value-creating opportunities across many jurisdictions with challenging environments. He also has significant global experience, with a focus on Nigeria and the wider West African markets. He has a hands-on approach, is always willing to assist new clients, is a great international networker, and is in the process of setting up Henley & Partners’ enhanced Nigerian–West African operations.