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Oral evidence part 1: Giving evidence abroad in the First-tier Tax Tribunal
Krishna Mahajan
Krishna is a Senior Associate in the Dispute Resolution Team, who specialises in litigation and resolution of complex tax matters.
Krishna has extensive experience in tax and trust litigation including working on Codes of Practice 8 and 9, cross-jurisdictional schemes with UK tax implications, settling EBTs and film finance schemes with HMRC, and concluding long standing HMRC enquiries. Krishna assists agents and companies who have made R&D claims that are being investigated, including COP8s and lengthy information requests under Schedule 36 of Finance Act 2008. Krishna is studying to become a qualified member of the Association of Tax Technicians.
Krishna acts for corporate clients, high-net-worth individuals, trustees and personal representatives regarding HMRC disputes and investigations in all areas of tax.
Areas of expertise
- Tax disputes and investigations
- Tax investigations involving complex trust structures
- Investigations involving cross-jurisdictional schemes with UK tax implications
- Code of Practice 8 investigations where HMRC suspect that the taxpayer has deliberately tried to pay less than the correct amount of tax
- Code of Practice 9 investigations where HMRC suspects deliberate fraudulent behaviour
- Voluntary disclosures for corporates and high-net-worth individuals
- Bringing longstanding complex HMRC enquiries into a client’s tax affairs to a close
- Advising on professional negligence matters relating to tax advice
recent experience
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Acting for trustees of complex structures in relation to disclosures to HMRC in respect of unpaid tax
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Assisting clients who entered into tax avoidance schemes to mitigate penalties and agree time to pay arrangements
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Acting for R&D agents who have had a number of enquiries made into their client’s claims, including the preparation of detailed responses to Schedule 36 Information Notices which have successfully mitigated penalties and limited the scope of the enquiry
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Acting for groups of companies and individuals in relation to claims against tax scheme promoters and advisors who gave negligent advice
PUBLICATIONS & PRESS HIGHLIGHTS
- Why tax lawyers and accountants should be friends not foes, Accountancy Daily, March 2024
