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Are you or your client facing a tax investigation and/or a 60% penalty (or worse) for a tax scheme defeated by HMRC using the General Anti-Abuse Rule or GAAR? Are you an adviser who enabled a tax scheme that has been defeated by HMRC, and now facing potentially ruinous enabler penalties as a result?
If so, you should seek specialist advice from a legal adviser with experience and a proper understanding of the GAAR.
The GAAR and its related penalties is a highly specialised and complex area of tax law. Patrick Cannon is the author of GAAR: A Practical Approach and has over 30 years’ experience as a solicitor and then a barrister, successfully defending clients in HMRC tax investigations – both criminal and civil.
Patrick is authorised by the Bar Standards Board to accept Public Access work and to conduct litigation – that is to accept work directly from clients and to deal directly with HMRC on their behalf.
Patrick works on the basis of fixed fees agreed by the client in advance with his Clerk instead of open-ended hourly rates. If you have a GAAR or related penalty enquiry, please contact Patrick Cannon here for an initial discussion.
Fees are discussed and agreed with my Clerks and are normally for a fixed amount for each piece of work, and agreed in advance. That way, you have certainty over the fee. For Public Access work, the agreed fee is payable in advance.
Yes, you will be sent the standard terms of engagement setting out the scope of the work Patrick Cannon will do for you, along with the agreed fee and various other terms and conditions. You will be requested to confirm your agreement to these terms before he commences work.
Patrick Cannon can advise you in person, by video call, by telephone, or in writing. He can also meet and discuss the case with your professional advisers or represent you in meetings with HMRC.