Her Majesty's Revenue and Customs (HMRC) is heavily scrutinising client engagement letters for evidence of tax evasion, a leading tax lawyer has warned advisers.
The letters, which detail the actions and activities an adviser is prepared to undertake for a client, form the basis of the parties' contract for services. Adrian Shipwright, director at law firm Allington Eames, told delegates at the Personal Finance Society (PFS) conference in Birmingham the letter is used by HMRC investigation teams to show intent of evasion. "Take care with your letters of engagement. The Revenue is crawling all over them. If your engagement letter essentially says what's proposed is a tax fiddle, when HMRC looks over it, it will say it is a tax fiddle." Where...
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