Sarah Woodall, Partner (Barrister), Head of Tax

Accountancy firm Howards Chartered Certified Accountants recently asked Sarah Woodall for urgent advice with a Stamp Duty matter.

The payment of stamp duty had been overlooked by HMRC on a very large transfer of shares going back to 2014. The company was being sold and the vendors faced an enormously disproportionate penalty proposed by the purchasers if the matter was not resolved within 90 days. HMRC had indicated it was impossible to resolve matters within this timeframe.

Sarah’s extensive knowledge of HMRC’s inner workings, key contacts, and her commitment to achieving the best possible outcomes for her clients, enabled her to cut through a web of slow and bureaucratic processes, and resolve the issue with HMRC amicably and by agreement within two weeks.

Sarah said: “I had every sympathy for the client. At times, HMRC’s correspondence failed to give email addresses or even a telephone number, and some letters provided telephone numbers that did not exist and excluded the name of the HMRC officer who had sent them.

“It was a big relief to all concerned, including me, that the potential penalty was avoided and that ultimately HMRC did go the extra mile to resolve what had been a really difficult issue.”

Matthew Bailey, Director at Howards, said: “The excellent outcome and time taken to resolve this time pressured issue went well beyond and above our expectations… [settling this matter was] a bright end to a dull day. I thank you from my heart for your help.”

Having worked with Sarah Woodall at HMRC, Jeremy Clarke-Morris, partner at Kendall Wadley accountants, knew she had a unique insight into counter avoidance investigation and systems.

In an Employee Benefit Trust (EBT) disguised remuneration case, he recommended Sarah act in a very large HMRC investigation by their Counter Avoidance and subsequently Fraud Investigation Service (FIS). The investigation settlement agreed was about quarter of £1 million less than would have been the case without Sarah’s relentless challenge- the client expressed delight and relief at the outcome.

Her in depth knowledge of HMRC, EBTs and ERTs ensured the best possible settlement for the client. Jeremy Clarke-Morris said “Our client was delighted. Sarah is highly professional, eloquent and had a very effective, down to earth approach. She is an excellent negotiator.”

Sarah said: “I have enjoyed working with Jeremy for many years and it was my pleasure to advise his client to resolve what was undoubtedly a difficult and long-running HMRC investigation. The client had found the situation stressful. It was satisfying to settle all matters by agreement and without recourse to the tax tribunal, ultimately with a very significant adjustment in the taxpayer’s favour, no penalties and with five years to pay.”

After a highly successful round of crowdfunding, entrepreneurial Herefordshire business A Rule of Tum sought the help of tax barrister Sarah Woodall in order to release half a million pounds of investors’ money.

The award-winning business needed to support its continued growth with increased investment and turned to crowdfunding. Having raised £500,000, advanced clearance from HMRC under the Enterprise Investment Scheme (EIS) was then needed to enable Rule of Tum to access the money. (EIS is designed to enable companies to raise money to grow by offering tax relief to individual investors buying new shares in a company.)

Unfortunately, long delays by HMRC and a failure to consider the merits of the case fully cost the business several months, and threatened to undermine investor confidence altogether. In need of urgent help, they turned to Sarah, whose experience of working with HMRC proved invaluable when advocating on business’s behalf.

Sarah’s precise and unequivocal demonstration of A Rule of Tum’s focus, providing members of the public with outstanding simple, locally sourced, seasonal foods in an environmentally sensitive manner, proved pivotal in obtaining clearance from HMRC and protecting the business’s investment which had been at risk.

Director Dorian Kirk said: “Just want to say thanks again for all the extra effort (Sarah) put in to get this over the line. We are utterly delighted.”