Steven’s Recent Experience Includes:
- IR35 Investigations: Lead solicitor on five IR35 investigations involving multinational large businesses in the Oil & Gas and Retail sectors. Beyond addressing disclosure and rectification of errors, Steven provided strategic advice on restructuring off-payroll workforces to effectively manage IR35 tax risks and ensure compliance with regulatory requirements.
- Dalriada Pensions Trustees v HMRC [2023] UKFTT 314 (TC): Represented Dalriada Pensions Trustees following their appointment by The Pensions Regulator. The case examined the tax implications of transactions implemented by the previous trustees. Six registered occupational pension schemes, collectively known as the Ark Schemes, operated a “pensions reciprocation plan” (PRP), designed to provide members with early access to pension capital without triggering unauthorised payment charges.
- Corporate Criminal Offence (CCO) Investigation: Supported a multinational construction company during an investigation into the Corporate Criminal Offence of failing to prevent the facilitation of tax evasion. The team conducted a detailed review of the company’s records to identify root causes of errors related to employment status and VAT compliance. The team assisted in preparing a comprehensive disclosure to HMRC and provided guidance on improving internal processes and controls to mitigate future risks and ensure compliance with CCO requirements.
- Code of Practice 8 (COP8) Enquiry: Assisted a large business in navigating multiple HMRC investigations, including a significant internal review prompted by a COP8 enquiry. The investigation centred on payments made to third parties connected to individuals with public profiles, with HMRC alleging these payments could constitute employment income or fall within disguised remuneration legislation. Steven conducted an analysis of the organisation’s records to address these complex allegations.
- UK Residency Enquiries: Successfully advised a number of High-Net-Worth Individuals (HNWIs) on HMRC enquiries into their UK residency status, ensuring compliance and resolving disputes effectively.
- Worldwide and Contractual Disclosure Facilities: Advised a range of HNWIs on disclosures to HMRC under the Worldwide Disclosure Facility and the Contractual Disclosure Facility. Recent work includes acting for a HNWI facing criminal prosecution for tax evasion. Steven’s intervention convinced HMRC to engage civilly, despite the absence of formal COP9 protections.
