Tax disputes don't have to be taxing.

Our elite UK Tax Solicitors & Barristers confidentially advise you on the merits of your tax case and negotiate with HMRC, so you don't have to. ☎ 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:

How to Respond to COP8 & COP9 HMRC Tax Investigations (2026 Guide)

HMRC’s COP8 and COP9 investigations are the most serious forms of UK civil tax enforcement. What begins as a “civil” enquiry can quickly escalate into a fraud investigation with criminal consequences. Early missteps—unguarded explanations, incomplete disclosure, or poor strategy—often determine the outcome. This guide explains how these investigations work, the risks they carry, and how taxpayers can protect themselves. In high-stakes HMRC disputes, expert legal control is decisive.
Read More
HMRC behaviour assessments determining careless, deliberate, or concealed conduct in UK tax penalty disputes

HMRC Behaviour Assessments: Careless, Deliberate, or Concealed?

HMRC behaviour assessments play a decisive role in tax disputes, affecting penalties, assessment time limits, and enforcement risk. This article explains how HMRC classifies conduct as careless, deliberate, or concealed, examines Tribunal authority, and sets out strategic defence and penalty mitigation approaches.
Read More
Cryptocurrency HMRC Enquiries & Tax Investigations

HMRC Crypto Information Requests: What UK Taxpayers Must Disclose

HMRC is intensifying its crackdown on cryptocurrency tax compliance, using exchange data, international reporting, and formal enquiries to identify undeclared gains and income. This article explains how HMRC crypto investigations arise, the legal framework governing disclosure, penalty risks, and how specialist tax dispute lawyers challenge HMRC assessments and enforcement action.
Read More
HMRC R&D tax relief enquiries and the need for statutory and Tribunal-based legal defence.

R&D Tax Relief Enquiries & Penalty Mitigation

HMRC R&D tax relief enquiries are increasing, with businesses facing claim clawbacks, penalties, and prolonged investigations. This in-depth guide examines how HMRC challenges R&D claims, the significance of Quinn (London) Ltd v HMRC, and how specialist legal defence can protect relief and mitigate penalties.
Read More

Section 396B ITTOIA 2005: HMRC Phoenixing TAAR & Winding-Up Distributions Explained

Section 396B of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA) is a targeted anti-avoidance rule (TAAR) that affects many owner-managed companies, landlords operating through corporate vehicles, and high-net-worth individuals planning solvent liquidations. It allows HMRC to reclassify certain winding-up distributions as income, rather than capital, where the taxpayer goes on to carry out the same or a similar trade. This can dramatically increase the tax payable, particularly where shareholders expected capital gains treatment or Business Asset Disposal Relief, and instead face higher dividend rates. Unsurprisingly, Section 396B issues now feature regularly in HMRC enquiries, compliance checks, and…

Read More
Explanation of HMRC Personal Liability Notices and how directors can defend allegations of fraud or neglect to avoid becoming personally liable for unpaid NICs.

Personal Liability Notices (PLNs): Defence Strategies for Directors

HMRC’s growing use of Personal Liability Notices exposes directors to personal financial risk for unpaid NIC liabilities. This detailed guide explains how PLNs work, HMRC’s legal tests for fraud or neglect, common investigative errors, and the defence strategies that can prevent directors becoming personally liable. Early specialist representation is essential.
Read More
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

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.

search previous next tag category expand menu location phone mail time cart zoom edit close