Background
Parousia was instructed by a high-net-worth individual with substantial commercial and residential property interests, together with ownership of a food manufacturing business. HMRC had been enquiring into their affairs for many years.
At the centre of the matter was a significant dispute concerning the historic valuation of business goodwill, an issue carrying potentially substantial tax liabilities. Years of correspondence had passed without resolution, leaving the client's affairs unsettled and the eventual exposure unquantified.
Our approach
Parousia began with a detailed review of the full history of the enquiries and the technical basis on which HMRC had built its case, rather than negotiating from the position HMRC had already established.
That review identified a serious deficiency in HMRC's original approach to the goodwill valuation issue. Parousia challenged HMRC's position robustly on that technical ground.
Outcome
HMRC ultimately withdrew its arguments concerning the disputed goodwill values, resulting in tax savings for the client in excess of £5 million.
Parousia subsequently brought the wider enquiries to a conclusion through a negotiated contract settlement with HMRC, providing the client with certainty and drawing a line under many years of tax enquiry and dispute.