Sophie Warren

Expertise

Sophie is a Senior Tax Manager in the Tax Disputes and Investigations practice. With over 14 years of experience, she advises corporates and high-net worth individuals (HNWIs) on a wide range of tax disputes and investigations. Sophie covers the full range of HMRC interventions from routine enquiries through to fraud investigations and prosecutions by HMRC’s specialist teams. 

Sophie has particular specialism in tax investigations involving suspected fraud under HMRC’s civil Code of Practice 9 (COP9) and assisting clients with voluntary disclosures of tax irregularities, helping clients resolve contentious issues and reach satisfactory settlement without recourse to litigation. 

• COP9 under Contractual Disclosure Facilities: Recent work includes acting for a HNWI facing criminal prosecution for tax evasion. Sophie’s intervention convinced HMRC to engage civilly, despite the absence of formal COP9 protections. 
• Digital Disclosure Service (DDS) and the Worldwide Disclosure Facility (WDF): Recent work includes acting for a HNWI on making a disclosure to HMRC in respect misappropriation of the Director’s salary to his wife to make use of lower marginal rates of tax. Through tax analysis and disclosure, HMRC accepted careless errors, and they did not constitute criminal behaviour. Advised a range of HNWIs on disclosures to HMRC of tax irregularities relating partly or wholly to an offshore issue under the WDF. 
• HMRC Criminal Investigation regarding the taxation of cryptoassets and HMRC’s ability to recover corporation tax from a dissolved company. Sophie helped to unify the criminal and tax elements of the matter and aided the client with a proposed settlement to HMRC. 
• UK Residency Enquiries: Successfully advised a number of HNWIs on HMRC enquiries into their UK residency status, ensuring compliance and resolving disputes effectively.