HMRC have a high net worth unit to deal with those with net wealth of over £20m (although there is some flexibility on this and is falling to £10m). This was thought to be around 5,000 UK taxpayers at the £20m level when the unit opened in April 2009.
Update January 2017: HMRC agent update 57 confirmed that the £10m+ criteria is now in place, the advantages of being able to email your “customer” relationship manager and to transfer to the unit on request.
Overall my experience with the unit for clients has been excellent. They take a sensible and pragmatic approach on most matters.
Examples include those planning to emigrate with uncertain and untested aspects of the Statutory Residence Test and a share disposal that may have not qualified for Entrepreneurs’ Relief unless a shadow director argument could be sustained. I’ve even migrated clients to the unit for the better service.
One potential downside of being within the unit is greater scrutiny of the tax return but this may be outweighed by having fully-trained inspectors dealing with the return and a direct line of communication with a named HMRC individual rather than the call centre.
Each taxpayer is risk assessed, with those on higher risk ratings being given greater attention.
Should the agent for the taxpayer take the initiative and drive the process forward with HMRC, to demonstrate the genuine risk level and notify in advance potentially unusual tax return entries? You may even begin to feel like a “customer”.