Services we offer

• Business and Company Compliance Checks conducted under HMRC’s formal enquiry powers (Corporation Tax & Income Tax) and informal enquiries (nudge letters; ‘discovery’ enquiries)

• Wholly and Exclusively (s34, ITTOIA 2005; s54 CTA 2009)

• Capital v Revenue (s33 ITTOIA 2005; s53 CTA 2009)

• Trading income (s5 ITTOIA 2005; s35 CTA 2009)

• Residence and domicile enquiries, including long-term and internationally mobile taxpayers (ITA 2007; Sch 45, FA 2013)

• Individual Compliance Checks involving complex or high-value affairs

• VAT inspections and assurance visits (VATA 1994)

• HMRC taskforce interventions and targeted campaigns

• Furlough and COVID-19 support scheme enquiries, including CJRS and Eat Out to Help Out (Coronavirus Act 2020; FA 2020)

• Employer Compliance Reviews, including PAYE, NIC, benefits and expenses (ITEPA 2003; Social Security Contributions and Benefits Act 1992)

• Schedule 36 information notices and document requests (Sch 36, FA 2008)

• Strategic management of third-party and financial institution notices (FIN’s)

• Challenging the scope, lawfulness, and proportionality of HMRC information demands

• Controlling enquiry conduct, delay, and procedural fairness (Litigation Settlement Strategy; HMRC Charter; Openness & Early Dialogue)

• Representations against penalties and behaviour allegations (Sch 24, FA 2007; Sch 41, FA 2008; Sch 55 FA 2009)

• Code of Practice 8 (COP8) investigations involving complex, high-value, or technically contentious issues

• Code of Practice 9 (COP9) civil fraud investigations under HMRC’s Contractual Disclosure Facility (CDF)

• Allegations of deliberate conduct, offshore non-compliance, and concealment

• Disguised remuneration and Employee Benefit Trust (EBT) enquiries (ITEPA 2003, Part 7A)

• Management of parallel civil and criminal exposure

• Early-stage advisory support in HMRC criminal investigations (Police and Criminal Evidence Act 1984)

• Statutory reviews and internal HMRC appeals (TMA 1970)

• Alternative Dispute Resolution (ADR) for direct and indirect tax disputes

• Preparation and conduct of appeals to the First-tier Tribunal (Tax Chamber)

• Litigation strategy, technical analysis, and evidential preparation

• Settlement negotiations and dispute closure on controlled terms

• Personal Liability Notices (PLNs) and joint and several liability cases (FA 2020; FA 2021)

• Transfer of company tax liabilities to directors or officers

• Director Loan Accounts (Chapter 3, CTA 2010; s175, ITEPA 2003)

• Distributions (s1000 et seq., CTA 2010)

• Defence of director conduct allegations and insolvency-linked tax claims

We work closely with accountants, tax advisers, insolvency practitioners, and legal professionals; providing discreet technical support, strategic oversight, and independent review in contentious and high-risk tax matters. Engagements are structured to complement existing client relationships and to provide clarity, assurance, and risk management where specialist disputes expertise is required.

• Strategic oversight and second-opinion support on HMRC enquiries that do not warrant full external appointment

• Procedural and technical review of HMRC correspondence, information notices, and enquiry conduct (including Schedule 36 FA 2008)

• Independent critique and risk assessment of tax advice, structuring, and planning, including contentious or historic positions

• Formal written technical opinions on tax risk, exposure, and defensibility

• Support to insolvency practitioners in cases involving HMRC claims, director conduct, and personal liability (including PLNs)

• Advisory input on disputes arising in administrations, liquidations, and bankruptcies

• Assistance with HMRC Mandatory Tax Adviser Registration and compliance obligations, including engagement with HMRC and disputes in this field

• Discrete advisory support in cases involving potential civil fraud, deliberate behaviour, or criminal exposure

• Tribunal and litigation support to legal teams, barristers and KC’s, including technical analysis and evidence strategy

• Assistance with Agent related matters (Public Interest Disclosures s18, CRCA 2005; Conduct Notices Sch38, FA 2012; Refusal to Deal With; withdrawal of Pay Now Check Later status)