The company was set up in June 2015 to provide a consultancy service to clients covering all areas related to Income and Corporation Taxes. A few of the more specialist services offered are considered in more detail below, but if there is anything tax related you need advice on a quick call or email is advised. The initial consultation is free and carries no obligation.

Our lead consultant is Mark Doodney. Mark spent 28 years working for HM Revenue and Customs and was Officer in Charge of the Barnstaple office at the time of its closure in May 2015. He completed the HMRC full technical training course, which is the highest level of technical training available within HMRC, and has worked in a variety of roles with a range of business sectors ranging from sole traders to large corporates.

As well as undertaking work for private clients, the company provides consultancy services to Croner Taxwise (formerly CCH) and the Stoke based Capital Allowance Review Service.

Capital Allowances

Mark worked as a Capital Allowances consultant for HMRC Head Office for several years prior to leaving HMRC, so is ideally placed to undertake reviews to ensure that all expenditure on assets qualifying for capital allowances, including historic embedded assets, has been claimed.

Work over the last few years has included the successful defence of a £1.2M retrospective allowance claim prepared by a client that was subject to an HMRC enquiry which sought to disallow the vast majority of the claim. We have also been preparing, advising, and defending claims in respect of agricultural buildings and structures that perform an ‘active function’ in the business.

Following the favourable First Tier Tribunal decision in respect of a grain store/silo found to perform the function of plant for capital allowances purposes in the case of May & Anor v Comms for HMRC ([2019] TC06928), in which Mark was heavily involved, we have worked with clients and accountants to submit successful claims to HMRC in respect of similar classes of assets.

We have an ongoing interest in developing this area and are currently working on various claims, including a substantial claim in respect of a climate controlled potato store for which counsel has been engaged and for which a First Tier Tribunal date is pending.

HMRC Enquiries

Mark has extensive experience of HMRC enquiry work having undertaken enquiries ranging from in depth reviews of the whole of the business operation (known as ‘full enquiries’ within HMRC) to technical enquiries focussing on certain areas only (‘aspect enquiries’).

In connection with this area we provide the following:

• Working with you and HMRC to bring enquiries to an early resolution through the addressing of enquiry risks.
• Reviewing the use of HMRC formal enquiry powers to ensure that their use is relevant, legally valid and within HMRC guidelines, challenging where appropriate.
• Negotiating enquiry settlements on your behalf with HMRC where necessary, to include consideration of restrictions to HMRC’s ‘discovery’ powers by reference to assessing time limits and other factors such as the concept of ‘staleness’, ensuring that your position is protected as far as possible.
• Undertaking penalty negotiations to ensure that any tax geared penalties sought are commensurate with omissions, errors and ‘behaviours’ established and are legislatively valid. We can also advise on other HMRC penalties as required.
• In more serious cases where a disclosure report is required as part of an HMRC enquiry into substantial and/or extensive failures to submit correct tax returns and pay correct taxes we can undertake this work and negotiate with HMRC on your behalf. In a recent case where we prepared a disclosure report we succeeded in obtaining HMRC agreement to a reduction in tax related penalties ofwell in excess of £50,000.
• Should a mutually acceptable enquiry settlement basis prove impossible to negotiate we can represent you through the use of formal internal review requests and Alternative Dispute Resolution (ADR) as appropriate. In the small number of cases where these ultimately prove unsuccessful we can advise, prepare for, and represent you at FirstTier Tribunal hearings./li>

A recent example of our work can be found in the case of Steadfast Manufacturing & Storage Ltd v Comms for HMRC([2020] TC07770). Mark, working in his capacity as a tax consultant for Croner Taxwise, defended a claim for tax relief in respect of repairs to the client’s premises, specifically the lorry yard, from the start of the enquiry process to success at the Tribunal.