SDLTM80290 - Compliance: Liaison

Special Compliance Office (SCO): Avoidance

SCO investigates cases involving suspected avoidance where there is a risk of loss of Revenue to the Exchequer and there is no provision elsewhere in the Department to deal with them adequately. This may be because a new or unusual device is being used, because investigation on an industry-wide basis is required, or perhaps because extensive third party investigation is necessary.

Such investigations may be very time consuming and difficult to fit into local programmes of work.

SCO avoidance groups are constantly on the lookout for cases where tax may be at risk in areas, which do not fall within the remit of other specialist offices. Many investigations are uncovered from project, and other review work, without local office involvement but appropriate cases, which come to light in local offices, should be referred to SCO.

The very nature of this work makes it impossible to provide rigid guidance as to what should be referred to SCO but current areas of interest include

  • company residence
  • UK companies with international issues
  • non-UK domiciled individuals
  • UK trusts and settlements
  • individuals in arrears, failure to notify etc
  • insolvency in avoidance cases

SCO will investigate only where the tax at risk is likely to be substantial but is prepared to take on speculative cases including those where the superficial risk is small but where there is potential to uncover greater liabilities.

Any case, which involves any of these or other aspects, and where avoidance of tax may be a possibility, should be referred to a compliance manager for guidance.