Tax Risk Evaluation and Mitigation Schemes
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The tax climate in the UK has changed significantly in recent years and HMRC are increasingly likely to challenge arrangements they regard as excessive tax planning. There are also increasing obligations to disclose information about certain transactions or arrangements as they arise, creating further administrative burden on all taxpayers (including those who may not even be knowingly engaging in tax avoidance).
Why use CMS for tax risk evaluation
Appetite for tax risk varies considerably from taxpayer to taxpayer. At CMS, we have considerable experience advising clients at both ends of the spectrum, including advising on how commercial transactions are likely to be perceived by HMRC, the courts or other authorities (e.g., under the Banking Code of Conduct).
Why use CMS for tax mitigation schemes
We also advise in relation to both the effectiveness of tax schemes and any potential recourse against scheme promoters and advisers. Our experience includes advising on schemes involving films, employee incentives, SDLT planning, specific tax deductions/reliefs and inheritance tax planning.