Got a tax dispute with HMRC?
Our ex-HMRC specialist tax lawyers can be instructed to assist you to resolve your dispute. They will deploy their decades of first-class experience in handling and carefully managing HMRC whilst guiding you on complex tax legislation and strategising to get you the best possible result. It’s important for individuals and businesses facing tax disputes to seek professional advice in order to navigate the complexities of tax law and procedures.
What is a Tax Dispute?
A UK tax dispute is a disagreement between a taxpayer and the tax authority (HM Revenue and Customs – HMRC) regarding the interpretation or application of tax laws. This can arise due to differences in the calculation of taxable income, disputes over allowable deductions, or the application of tax credits, or disagreements about the overall tax liability.
Tax disputes can occur at different stages of the tax process, including during the filing of tax returns, during tax audits or investigations by HMRC, or even during the appeals process if the taxpayer disagrees with an assessment or decision made by the tax authorities. When a tax dispute arises, it’s common to instruct professionals to engage in discussions with HMRC to resolve the issue.
Unlike a solicitor who by law must provide an entirely confidential legal service, an accountant has no legal duty of confidentiality and will have little to no skill in managing tax litigation; we have seen numerous cases where an accountant has disclosed material that we as solicitors would not be able to disclose and also worsened the client’s position with HMRC. Our team of ex-HMRC barristers and solicitors can carefully manage tax disputes by reviewing and providing additional documentation, clarifying positions, or negotiating a settlement with HMRC. In some cases, taxpayers may appeal decisions to independent tax tribunals or courts if an agreement cannot be reached through negotiation. Alternative dispute resolution mechanisms, such as HMRC mediation, may be explored as a way to resolve conflicts outside of formal legal proceedings.
We are Former 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
Total number of taxpayers in the UK (2022)
Appeals
Outstanding HMRC Tax Tribunal appeals (2022)
Success
Tax appeals settled without hearing (2014)
Loan Charge
Disguised remuneration loan charges (2019)
(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.
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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
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
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.
Our Areas of Expertise vs HMRC:
We regularly take on HMRC tax cases in these areas:
HMRC TAX APPEALS
Expertise in dealing with:
Penalty appeals: Self Assessment penalties; PAYE/NI; late payment penalties; late VAT returns; late returns; corporation tax penalties; HMRC Internal Reviews; Notice of appeal to HMRC
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
TAX EVASION & HMRC INVESTIGATIONS
COP 8, 9 & 11 investigations; section 144 enquiries; tax avoidance schemes advice: EBTs, SDLT avoidance, IHT schemes; voluntary disclosure; offshore tax evasion; disguised renumeration
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.
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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 Articles from our team of tax solicitors and ex-HMRC barristers:
IR35 Tax Rules: Adrian Chiles’ Tribunal Appeal Highlights Challenges for UK Contractors
The recent tax battle between Adrian Chiles and HMRC over IR35 Tax rules or off-payroll working rules has cast a spotlight on this complex piece of UK tax legislation. Many…
Judicial Review of HMRC Decisions: A Guide to the Application Process
The Administrative Court Judicial Review Guide 2024 has been released, serving as an essential resource for individuals and businesses engaged in judicial review claims, particularly in tax disputes with public…
Closure Notices and HMRC’s “Fishing Expedition” (HMRC v Jonathan Hitchins & Ors)
In HMRC v Jonathan Hitchins [2024], the Upper Tribunal upheld the First-tier Tribunal’s decision, requiring HMRC to issue closure notices for prolonged enquiries into the Hitchins brothers’ tax affairs. The…
Historic MTIC VAT Fraud Directors Owe £4.8m (18 Years Later)
The High Court has found directors liable for a £4.5 million VAT MTIC fraud perpetrated by their company, Phoenix Tech Ltd which was long ago determined by the Tax Tribunal…
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.