Tax Disputes & Investigations

High Net Worth Unit (HNWU)

HM Revenue & Customs' (HMRC) High Net Worth Unit (HNWU) is part of its Charity Assets and Residence (CAR) Department. The Unit was launched in April 2009. HMRC sited it within CAR specifically so there could be 'clear lines of sight' to/with other parts of that Department such as Inheritance Tax, Trusts/Charities and Pensions.

On this page:

• History
• Rationale
• Aims and Objectives
• Who is a HNWU 'customer'?
• Has the HNWU been a success?
• How can OneE TDI help?
• How can I contact OneE TDI?

History

In early 2009, HMRC reorganised its Complex Personal Tax Teams (CPTT) and Expatriate Tax Teams. In essence, the CPTT was disbanded and a smaller HNWU created. The expatriate work was moved into its Personal Tax International business unit, which now deals with inward bound expatriates and some non-resident or non-domiciled individuals, partnerships and companies.

The decision to create the HNWU was clearly influenced by an OECD initiative (which was reported as 'Engaging with High Net Worth Individuals on Tax Compliance' (the HNWI Report))

The HNWI Report recommended a number of best practice methods for dealing with wealthy individuals, including: -

• introducing/developing strategies to help counter aggressive tax avoidance;
• creating dedicated units to specifically handle the affairs of High Net Worth Individuals (HNWIs) and ensuring that such initiatives are properly resourced and staffed by experienced officers;
• establishing a framework for dialogue between HNWU officials, HNWIs and their advisers;
• creating Customer Relationship Managers (CRMs); and
• developing a good commercial awareness of the broader concerns of HNWIs

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Rationale

The tax affairs of most HNWIs are complex and often include multiple sources of income from different sources in differing jurisdictions. To help improve tax compliance by this sector of the population, HMRC has to better understand the business arrangements involved.

In the UK, the top 0.5% of taxpayers pays 17% of the total Income Tax collected in the UK. Their contribution to the Inheritance Tax 'take' is even higher. HMRC knows that this group of taxpayers often seeks to mitigate its tax exposure by careful tax planning and its compliance strategy must address this issue.

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Aims and Objectives

The HNWU's stated aims are: -

• to build relationships and develop its commercial awareness to help it better understand HNWIs;
• to make it easier for HNWIs to get things right;
• to provide HNWIs with a better service by way of 'pro-active engagement' and a single point of contact; and
• to encourage open communication between all parties to achieve a swift resolution of any tax issue.

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Who is a HNWU 'customer'?

Since it was created, the HNWU has sought to refine its customer base so that it only deals with the 5,000 (approx) wealthiest taxpayers in the UK. In essence, this includes individuals with investible assets of at least £20Million.

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Has the HNWU been a success?

The CPTT broadly dealt with 45,000 (approx) cases. Using similar staffing levels, the HNWU has been dealing with only 5,000 (approx) cases. This means that greater resources have been available to the HNWU to investigate the affairs of wealthy individuals and its results for its first year show that it secured additional tax of £85Million. This compares favourably with the £25Million being brought in previously each year by the CPTT.

The HNWU is at the forefront of HMRC's campaign to target and combat tax evasion and unacceptable tax avoidance by wealthy individuals.

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How can OneE TDI help?

At the core of OneE TDI is a highly experienced team specialising in all areas of tax disputes and investigations work. We offer confidential, non-judgemental advice to best defend our clients and have a proven track record in successfully managing all contentious tax matters. We provide an outstanding, cost effective service, which results in tangible benefits and savings for our clients. Our advice saves our clients time and money and helps reduce their potential exposure to tax, interest and penalties.

We take control of and manage all parts of a CAR investigation so that our clients can get on with their life and their business. What price peace of mind?

Please see the Testimonials kindly provided by our clients (or their accountants or lawyers), which confirm our levels of client service.

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How can I contact OneE TDI?

If you would like a free, no obligation discussion with us please contact either Gary Rowson or Mark Taylor on 0800 652 6156 or complete and submit the form below.

Whilst we endeavour to provide informative and accurate information, the content on this site is for general information purposes only and should not be taken to constitute tax or legal advice which must always be tailored to individual circumstances. Please contact us if you would like to discuss matters.

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