International tax request: Interlegal will help to find an answer
8 April, 2025
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Recently, Interlegal law team helped one of our Clients to reply to a request from the UK’s tax, payments and customs authority (HMRC). Legal assistance was initiated by the Ukrainian tax office that actively applies interstate tax conventions as a tool for controlling and obtaining tax information about foreign companies, trusts and partnerships.
Case plot
The Client’s group included a partnership registered in the United Kingdom and engaged in trade of agricultural products, in particular, with Ukrainian counterparties.
The HMRC request concerned two principal aspects:
- The Client’s partnership operations with a Ukrainian company from 2015 till 2019;
- Information about activities of the partnership and its assets in general.
At the moment of receiving the request, the partnership had not been actively operating for several years and had no full-time employees, which made it difficult to prepare a comprehensive response.
How did we help?
- Extension of the deadline for providing a response. First of all, Interlegal lawyers drafted a statement for HMRC justifying impossibility to provide a response in due time and requesting extension of such deadline. The statement was satisfied and the Client received additional time for high-quality preparation and collecting information.
- Resolving the issue concerning documents. The UK tax office requested accounting documents, the retention period whereof under English law had already expired. It was necessary to find out whether it was treated as sufficient legal grounds for not providing documents at the HMRC request, as well as to assess potential risks of such a decision both for the partnership and the Client.
To resolve this issue, Interlegal UK associated office has been involved in the process.
- Drafting a response to the request. Interlegal law team, jointly with British colleagues, prepared a response to the HMRC request that, on the one hand, took into account the Client’s interests and mitigated its risks, and, on the other hand, satisfied in full tax office’s requirements and did not entail negative effects in England.
- Recommendations upon further actions. We also provided recommendations to our Client on how to properly communicate with British tax offices for avoidance of additional requests.
Result
Due to our support, the Client was able to provide the required information to English tax office in due time and received no more requests from HMRC.
Interlegal law team led the project: junior lawyer Oleksandra Savielieva and managing attorney Dmytro Bondar, managed by partner Irina Voyevodina.
We are ready to help you too!
Interlegal provides assistance in preparing replies to tax office’s requests, legal support of tax inspections and legal advice upon tax legislation.
For any details, please contact Interlegal Corporate and Taxes managing attorney Dmytro Bondar.
