Tax disputes don't have to be taxing.

Our ex-HMRC Tax Solicitors & Barristers can assess the merits of your tax case and negotiate with HMRC to get you the best result. ☎ 02071830529

HMRC Tax Dispute Lawyers

Facing a tax dispute with HMRC? Our team of ex-HMRC tax barristers and solicitors can help you reach the best possible outcome. With decades of experience dealing directly with HMRC, we know how to manage investigations, negotiate settlements, and defend your position using proven legal strategies. Whether you are an individual or a business, getting confidential legal advice from qualified lawyers – not from accountants – can make all the difference in protecting your finances and reputation.

ACCOUNTANTS HAVE NO LEGAL DUTY OF CONFIDENTIALITY

Many taxpayers don’t realise that accountants are not legally required to keep your information confidential. Unlike solicitors, who must protect every detail of your case by law, accountants can – and often do – disclose sensitive information to HMRC. This can severely damage your position in a dispute.

Our team of former HMRC solicitors and barristers are experts in protecting your rights and resolving tax problems. We know exactly how to manage your case, control what is disclosed, and negotiate effectively with HMRC. If needed, we can also appeal to tax tribunals or courts and explore mediation to achieve the best possible result.

Resolving HMRC Tax Penalties & Investigations

A tax dispute arises when you and HM Revenue and Customs (HMRC) disagree about how tax laws apply to your situation; whether that’s your income, deductions, credits, or an alleged underpayment. These disputes can start during tax returns, audits, or after HMRC issues an assessment or penalty.

When that happens, it’s vital to have experienced legal representation. Our solicitor and barrister team regularly deal with HMRC to resolve issues, reduce penalties, and protect clients’ interests; often fixing mistakes made or worsened by accountants.

We are ex-HMRC / Big 4 Tax Litigators

Our leading UK tax counsel served as a HMRC in-house tax barrister and as Head of Indirect Tax Litigation at Deloitte and National Tax Litigation Director at PWC. Our Senior Partner has worked at KMPG, Goldman Sachs and ING Barings and is dual-qualified as a Barrister and Solicitor-Advocate. Both lawyers will be available to you at the outset in your first advice conference.

Taxpayers

39.1m

Total number of taxpayers in the UK (2025-26)

Appeals

47,250

Outstanding Tax Tribunal appeals (2023-24)

Success

60%

Tax appeals settled without hearing (2014)

Resolved

7,081

Tax appeals resolved by hearings (2023)

(Source: HM Revenue & Customs and the Ministry of Justice)

We have decades of experience in negotiating with HMRC and managing appeals against their decisions at all levels. Members of the team include qualified Tax Solicitors and Tax Barristers whom have vast experience of tax laws and first hand commercial, litigation and advocacy experience including previously working at HMRC as senior Tax Counsel and managing Tax Tribunal appeals and defending tax related CPS prosecutions.

Our ⭐⭐⭐⭐⭐ Client feedback:


Instruct our Professional UK Tax Lawyers

Our dual-qualified Solicitor & Barrister team assess your case at the outset. We will quickly determine the merits and prospects of your tax dispute and then also advise you on how to obtain an optimal outcome.

CITY LAWYERS
CITY LAWYERS

Qualified tax solicitors & tax barristers with litigation and HMRC expertise. We are the only solicitors’ firm in England to operate from professional chambers in Middle Temple, London.

HMRC EXPERTS
HMRC EXPERTS

Our ex-HMRC tax barristers can advise on tax matters such as appeals, penalties, investigations, Tax Tribunal appeals, VAT evasion, MTIC fraud, COP 8 or 9, seized goods, disguised remuneration.

CONFIDENTIAL
CONFIDENTIAL

Our Tax Litigators provide legally privileged & confidential advice (unlike accountants and other non-legal tax advisers). Our expert tax lawyers are regulated by the SRA and BSB.


Our Areas of Expertise vs HMRC:

We regularly take on HMRC tax cases in these areas:

TAX TRIBUNAL REPRESENTATION

FTT, UTT & Court advocacy; indirect tax appeals representation (Income tax/VAT/excise duty/CGT/Corporation tax); First Tier Tribunal; Upper Tier Tribunal; Out of Time Appeals


Want elite advice from ex-HMRC Tax Counsel?

Want to challenge a HMRC tax penalty or fine? HMRC investigation? VAT issues? Problems with a disguised remuneration scheme or tax evasion? Need representation at the First Tier Tax Tribunal? 

We are a specialist leading City of London tax law firm based in Middle Temple (Barristers’ Inns of Court) adjacent to the Royal Courts of Justice.

Our expert tax solicitors and barristers have years of experience in of working with and negotiating with HMRC and managing appeals against their decisions at all levels. Members of the team include qualified Tax Solicitors and Tax Barristers whom have vast experience of tax laws and first hand commercial, litigation and advocacy experience previously working in-house for multinational accountancy firms and as senior counsel at HMRC itself.

Our experienced lawyers regularly carry out work in many tax disputes areas,  from advising clients on whether HMRC have followed the correct procedures to successfully challenging HMRC’s policies. We have specialist knowledge in HMRC internal processes as well as ensuring that we are able to successfully challenge HMRC decisions in the Tax Tribunals. We have a team of established tax and duties specialist lawyers with a proven track record of delivering authoritative solutions for our high net worth individual and corporate clients.

*Please note we do not undertake legal aid work and are normally only instructed on HMRC tax disputes that are of a substantial value (this is because legal costs are rarely recoverable in Tax Tribunal cases). Please see our costs page for more information.*


Don’t risk using an accountant against HMRC…

It is important to note that all client communications to accountants are not legally privileged and are easy for HMRC to obtain; however, communications to lawyers are legally privileged and highly confidential. Therefore it is beneficial to the success of many of our clients’ cases that we be instructed to instruct an experienced forensic accountant on your behalf. Although you may have instructed an accountant in relation to your accounts and tax matters for yourself or your business, in most cases your accountant should realistically only assist you in tax compliance matters whereas we specialise in assisting you in relation to any investigations that HMRC have brought against you. We regularly work with accountants to ensure that collectively we are able to obtain the best possible resolution to your matter.

Our ⭐⭐⭐⭐⭐ Client feedback:


Featured guide on HMRC Disputes & Investigations

The Company Director’s Guide on managing HMRC disputes

Our specialist tax team regularly provide market leading advice to directors of companies and limited liability partnerships.
Our work has featured in KSA Group‘s Worried Directors Guide 2018, including our authoritative guide on HMRC tax disputes and investigations.


Latest HMRC Cases & UK Tax Litigation News

UK Tax Litigation Legal News from London’s leading tax solicitors & barristers:

NIC reclassification dispute guidance for employers facing HMRC employment status investigations and PAYE liabilities

NIC Reclassification Disputes: Employment vs Self-Employment

Disputes over worker status can expose businesses to large PAYE and NIC liabilities, penalties, and interest. This detailed legal guide explains how NIC reclassification disputes arise, how HMRC conducts investigations, the key case law, and how to defend employment status challenges at Tribunal.
Read More

Delaying Payments During an Appeal

When a taxpayer appeals an HMRC assessment or penalty, they may not have to pay the disputed amount immediately. UK law provides powerful safeguards, such as postponed collection requests and hardship applications, that allow payment to be delayed while the dispute is resolved. This guide explains the legal framework, key Tribunal decisions, enforcement limits, and strategic considerations for delaying HMRC payment demands during an appeal.
Read More

Tribunal Rules No Jurisdiction on Legitimate Expectation in Tax Appeal

The First-tier Tribunal (Tax Chamber) struck out the appellant’s “legitimate expectation” ground in a tax residency dispute, confirming that the Tribunal lacks jurisdiction to determine public law defences such as legitimate expectation or abuse of power in appeals against Closure Notices under the Taxes Management Act 1970.
Read More
Royal Courts of Justice in London with subtle overlays representing international travel and HMRC tax scrutiny, illustrating the judicial review over IR20 residency guidance.

Judicial Review Granted Over HMRC IR20 Residency Guidance

In R (Houldsworth) v HMRC [2025] EWHC 2848 (Admin), the High Court allowed a taxpayer’s judicial review to proceed over whether HMRC’s former IR20 guidance created a legitimate expectation that he would be treated as non-resident while working full-time abroad. This ruling strengthens the position of taxpayers facing retrospective UK residency assessments.
Read More
Documents labelled “HMRC R&D Enquiry”, “Tax Relief Challenge” and “R&D Compliance Check” on a desk with a calculator, blueprint drawings and a folder titled “R&D Tax Credit Appeal – Evidence Pack”, representing HMRC disputes of R&D claims.

HMRC Rejected Your R&D Tax Relief Claim? Legal Defence Guide

HMRC continue to intensify their scrutiny of Research & Development tax relief claims, frequently disallowing expenditure and issuing penalties for alleged inaccuracies. However, recent Tribunal decisions show that companies can successfully challenge HMRC’s conclusions when technological or scientific uncertainty is evidenced properly.
Read More
Understanding how HMRC penalises late PAYE and NIC payments — legal guidance on reasonable excuse arguments and appeals before the Tax Tribunal.

Late Payment of PAYE & NIC: Penalties, Reasonable Excuse and Appeals

Late payment of PAYE and NIC can trigger automatic HMRC penalties, surcharges, and daily interest. However, many fines can be challenged successfully. This guide explains how to appeal PAYE and NIC penalties, what counts as a reasonable excuse, and how expert representation can protect your business from escalating enforcement.
Read More
HMRC voluntary disclosure form being reviewed to correct undeclared tax errors and reduce penalties

Voluntary Disclosure to HMRC: Reducing Penalties and Prosecution Risk

Making a voluntary disclosure to HMRC allows individuals and businesses to correct past tax errors, reduce penalties, and avoid criminal investigation. This guide explains how the process works, what HMRC expects, and why prompt disclosure can protect you from harsher enforcement and reputational damage.
Read More

Want legal advice from Tax Solicitors on your case?

Our simple enquiry form goes immediately to our tax litigators in Middle Temple, London. Call us on +442071830529 from 9am-6pm.

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