How UK Tax Investigation Experts Handle HMRC Disputes
When HMRC raises questions about a tax return, business records, VAT, compliance related to PAYE or historic tax planning, the situation can quickly become stressful.
A simple request for information can evolve into a formal HMRC enquiry, compliance check, Schedule 36 information notice, penalty dispute or even a high-risk tax investigation. Whether you’re an individual, director or run a business, getting the right advice early can make a significant difference to the final outcome.
At Fortis Tax, we advise and represent clients in disputes with HM Revenue & Customs at every stage of an enquiry, investigation or appeal. Our work is focused exclusively on contentious tax matters, which means we understand how HMRC approaches risk, evidence, procedure, settlement and litigation.
We combine technical expertise with strategic judgement, helping you protect your position, manage exposure and move towards a resolution efficiently.
Understanding the Nature of an HMRC Dispute
Not every HMRC dispute begins in the same way. Some clients come to us after receiving a letter that requires a ‘nudge’ or an informal request for clarification. Others face a formal check into Corporation Tax, Income Tax, VAT, PAYE, National Insurance contributions, benefits and expenses, residence, domicile or high-value personal tax affairs.
The first step for any tax investigation expert is to understand exactly what HMRC is asking, why it is asking, and what powers it is relying on. This is important because HMRC’s approach must be legally and procedurally sound. Where a request is too broad, disproportionate or unclear, it may be possible to challenge its scope.
Where HMRC has raised concerns about behaviour, disclosure, penalties or deliberate conduct, the response must be carefully managed from the outset.
At Fortis Tax, we look at both the technical tax position and the procedural framework. This allows us to identify the key risks, assess the strength of HMRC’s case, and develop a strategy that is measured, robust and appropriate to the circumstances.
Managing HMRC Enquiries and Compliance Checks
HMRC enquiries and compliance checks can cover a wide range of issues, from business expenses and trading income to capital versus revenue treatment, VAT inspections, employer compliance reviews and targeted HMRC campaigns.
In company and business tax disputes, HMRC may examine whether expenses were incurred wholly and exclusively for business purposes, whether income has been correctly reported, or whether records support the figures submitted.
A well-handled response should not simply provide documents without context. It should explain the position clearly, address the specific points raised, and avoid opening unnecessary lines of enquiry. Providing too little information can lead to escalation, but providing too much can create avoidable risk.
We help clients manage HMRC correspondence, prepare effective responses, review evidence, and ensure that the enquiry remains focused.
Our aim is to keep control of the process, reduce uncertainty and bring matters to a practical conclusion wherever possible.
Responding to Information Powers and Schedule 36 Notices
HMRC has formal information powers, including the ability to issue Schedule 36 information notices and request documents from taxpayers, third parties and financial institutions. These powers can be significant, but they are not unlimited. Requests must be relevant, proportionate and within the correct statutory framework.
One of the most important roles of a tax disputes specialist is to assess whether HMRC’s information demands are lawful and reasonable. In some cases, it may be necessary to challenge the scope of a notice, object to irrelevant requests, or make representations where HMRC’s approach creates procedural unfairness.
At Fortis Tax, we assist with procedural challenges, document requests, financial institution notices, penalty representations and disputes about enquiry conduct. We focus on protecting the client’s position while ensuring that HMRC receives properly managed, relevant information.
Serious and High-Risk HMRC Investigations
More complex disputes may involve Code of Practice 8 investigations, Code of Practice 9 civil fraud investigations, the Contractual Disclosure Facility, offshore non-compliance, disguised remuneration, Employee Benefit Trust enquiries or allegations of deliberate behaviour. These cases require specialist handling because the financial, reputational and personal consequences can be significant.
In serious tax investigations, early strategy is critical. The client needs to understand the potential tax exposure, the evidential position, the risks of penalties, and whether there is any parallel civil or criminal exposure. Responses must be accurate, consistent and supported by evidence.
We advise clients facing high-risk HMRC investigations with a clear focus on procedural control, technical analysis and strategic resolution. Our role is to reduce uncertainty, manage communication with HMRC and ensure that the client’s position is presented in the strongest possible way.
Dispute Resolution, Appeals and Litigation Strategy
Not every HMRC dispute is resolved through correspondence. Where agreement cannot be reached, clients may need support with statutory reviews, internal HMRC appeals, Alternative Dispute Resolution, settlement negotiations or proceedings before the First-tier Tribunal Tax Chamber.
A strong dispute resolution strategy considers both the legal merits and the commercial realities. It may involve technical submissions, evidential preparation, negotiation, mediation-style engagement or tribunal litigation. The right route depends on the facts, the value at stake, the strength of the arguments and the client’s wider objectives.
At Fortis Tax, we provide end-to-end representation from initial contact with HMRC through to the settlement. We prepare clients for each stage, assess risk carefully and pursue resolution on controlled terms. Where litigation is required, we work alongside the litigator on the development of a clear strategy based on evidence, technical analysis and procedural discipline.
Personal and Director Liability
HMRC disputes can also affect directors personally. This may involve Personal Liability Notices, joint and several liability, director loan accounts, company distributions, insolvency-linked tax claims or allegations about your conduct. These matters often arise where HMRC seeks to transfer or pursue company tax liabilities against individuals.
For directors, it is essential to obtain advice before responding to HMRC allegations or agreeing to any proposed settlement. The issues may involve company law, insolvency, tax legislation and questions of personal responsibility. A poorly handled response can make the dispute harder to resolve.
We assist directors, business owners and individuals with personal liability disputes, helping them understand the basis of HMRC’s position and identify the available grounds of challenge.
Support for Accountants, Tax Advisers and Legal Professionals
HMRC disputes often involve existing professional advisers who know the client and their affairs well. In these situations, our role is not necessarily to replace the adviser. We frequently work alongside accountants, tax advisers, insolvency practitioners, solicitors, barristers and KCs, providing specialist advice where contentious or high-risk issues arise.
We offer strategic oversight, second opinions, procedural reviews, technical risk assessments, written opinions, tribunal support and assistance with HMRC correspondence.
Why Seeking Specialist Advice Early Matters
The earlier a tax investigation expert is involved, the more options are usually available. Early advice can help prevent unnecessary disclosure, avoid procedural mistakes, challenge inappropriate HMRC requests, reduce penalty exposure and keep the dispute focused.
At Fortis Tax, our approach is measured, technical and strategic. We do not treat HMRC disputes as routine administrative matters. We assess the facts, identify the risk, control the process and work towards the most effective resolution available.
Whether you are an individual facing an HMRC enquiry, a director concerned about personal liability, a business dealing with a compliance check, or a professional adviser seeking specialist support, we can help you respond with clarity and confidence.
If you need advice on an HMRC dispute or tax investigation, contact Fortis Tax for specialist representation.