Rahman Ravelli’s expert team of lawyers is experienced in representing clients, whether individuals or companies, in a whole range of tax fraud cases; ranging from tax investigation advice to high profile prosecutions and from cases involving simple tax evasion through to complex structures across various industries and jurisdictions. We have appeared in the country’s most high-profile cases and continue to do so.
We provide assistance in both the civil and criminal arenas and are often called in by other professionals such as accountants to provide preventative advice and strategic planning.
We frequently assist clients and professionals in negotiating with HMRC and advising on the scope and consequences of disclosures e.g. in Code of Practice 9 (COP9) investigations.
Our reputation enables us to tailor a team which often includes our commercial litigation department and we are able to call upon leading barristers and international accountancy practices.
Types of cases
We have experience in advising clients involved in a whole manner of industries; from the construction trade and finance houses through to businesses involved in high tech components and commodities like steel, diamonds and textiles to name a few.
Whatever profession or commodity a client’s case involves and whatever the underlying tax that is under investigation, we can assist. We are recognised as providing a robust and proactive representation to achieve the right outcome.
We also have a particular expertise in representing clients in MTIC fraud cases.
Missing Trader Intra Community (MTIC) VAT Frauds (or carousel frauds) are often lengthy, complex investigations. This can be because the circumstances are complicated or because investigators want to take their time and have every opportunity to uncover anything that may be used as evidence.
If a person, company or organisation is the subject of such an investigation it is advisable to seek immediate advice. The penalties for carousel fraud are high.
Carousel frauds involve high-value goods being imported VAT free from E.U. countries. They are then sold on at VAT-inclusive prices and the original dealer (or a dealer further down the chain) then disappears without paying the VAT to the authorities. This is usually carried out more than once through a complex chain of companies and transactions. The goods may even be re-exported, with the exporter reclaiming the VAT from HMRC.
Prosecutors look to link transactions and companies to establish trading patterns. A legal defence team, therefore, must compile and analyse all possible evidence to back up their case that their client is innocent.
At Rahman Ravelli, we handle such cases strategically; using investigatory skills, forensic accountants and specialist barristers to research, prepare and present the strongest case possible.
We are involved regularly in high-profile examples of such cases that can often involve hundreds of millions of pounds, for example Operation Forbear, international carbon trading investigations such as Operation Tulipbox and its related case Operation Carp to name a few.
Our experience shows that cases may involve differing types of commodities – from scrap metals to mobile phones – but the principles of a strong defence remain the same. We challenge investigators to ensure our clients can continue with a decent quality of life while under investigation.
For example, a suspect may not know they are under investigation until their bank account is been frozen under a restraint order issued under the Proceeds of Crime Act 2002 (POCA). This makes it hard to run a business and maintain a family life – which is why expert legal advice must be obtained early. We are experts in handling POCA cases – using our recognised innovative and robust methods to make sure our clients under investigation can access their assets so their lives are not put on hold.
Given the broad variety of prosecutions, there can be no general advice to those faced with a 'cheating the revenue' type prosecution. But it is always worth remembering that despite the resources that the state puts behind prosecuting these cases the authorities can and do get it wrong, just as much as they can and do get it wrong in any other type of criminal case. There are pitfalls for the Crown: their case may sometimes be just too complex for a jury to be sure, they might confuse knowledge with participation in an importation case or the defence, through sheer hard work, may be able to show that a 'rogue trader' is in fact a legitimate businessman just trying to do his best. There might, in some cases, have to be a great deal of investigative or accountancy work to be undertaken by the defence team - or it simply may all come down to inferences from some phone traffic. Whatever the case, as usual, early preparation and keeping the maximum pressure on the prosecution are the only keys to a successful outcome.