Our client came to us on 30 October 2019 with a personal liability notice of £117,805.61 at 88% penalty loading as a shareholder of the company.
Already one tax investigation expert had represented this client hence our client stated he would be happy with even 10% reduction in his personal tax liability.
The CT PLN was reduced from £117,805.61 to £28,417.39. A saving of £89,388.23 which is a 76% reduction in his personal tax liability.
We established that the directors loan account was not overdrawn on this case.
There was considerable resistance from this HMRC caseworker. We had to request the caseworker to seek further technical advice as we had reached an impasse with the caseworker. This is an example of how you can disagree with the caseworker, but still work collaboratively and reach a resolution on the case. The caseworker then sought technical advice from an HMRC tribunal caseworker and senior manager, who agreed with our technical approach on the tax position. Fortunately, we reached a settlement without the need to go to ADR.