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Tax & HMRC Dispute Solicitors

An HMRC investigation, a tax assessment, a penalty notice, or a tax tribunal appeal — each requires specialist legal advice. A solicitor who understands tax law and the litigation process gives individuals and businesses the best chance of a cost-effective outcome.

HMRC has wide-ranging powers to investigate tax returns, raise assessments, issue penalties, and pursue unpaid tax through enforcement. Tax disputes are technical — the correct treatment of a transaction, the application of an exemption, the validity of a penalty, or the procedural fairness of an HMRC investigation can each turn on detailed legal analysis. A solicitor will advise on the merits of the HMRC position, respond strategically to HMRC correspondence, negotiate a resolution, and represent the taxpayer at the First-tier Tax Tribunal or the Upper Tribunal where a hearing is required.

HMRC investigations & enquiries VAT, CGT, PAYE & corporation tax Penalty appeals & tax tribunal Free initial consultation

Tax & HMRC Dispute Services

Every type of HMRC dispute and tax challenge — select the area that matches your situation.

HMRC Tax Investigations

Code of Practice 8 and 9 investigations, HMRC enquiries into tax returns, and civil investigation of fraud — specialist legal advice and representation throughout.

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VAT Disputes

VAT assessments, input tax disputes, HMRC decisions on VAT liability, default surcharge, and VAT penalty appeals — including First-tier Tribunal representation.

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Capital Gains Tax Disputes

HMRC challenges to CGT returns, disputes over relief entitlement (BADR, PPR, gift holdover), HMRC enquiries into asset disposals, and tax tribunal appeals.

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Corporation Tax Disputes

HMRC enquiries into corporation tax returns, transfer pricing disputes, R&D tax credit challenges, loss relief disputes, and HMRC assessments of additional liability.

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Inheritance Tax Disputes

HMRC challenges to IHT returns, disputes over business property relief, agricultural property relief, and the valuation of estate assets — and appeals against HMRC's assessment.

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PAYE & Employer Compliance

HMRC employer compliance reviews, PAYE assessments, National Insurance contribution disputes, and employer obligations for benefits in kind and expenses.

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HMRC Penalty Appeals

Appealing HMRC late filing, late payment, inaccuracy, and failure-to-notify penalties — including special reduction, reasonable excuse, and First-tier Tribunal representation.

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Self-Assessment Disputes

HMRC enquiries into self-assessment returns under s.9A TMA 1970, disputes over income classification, allowable expenses, and closure notices — and appeals to the tax tribunal.

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Tax Tribunal Appeals

First-tier Tribunal (Tax) and Upper Tribunal appeals against HMRC decisions — managing the litigation from notice of appeal through to final hearing and costs.

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IR35 Disputes

HMRC IR35 status determinations, off-payroll working rules challenges, defending IR35 investigations for contractors and engagers, and tax tribunal appeals.

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How It Works

HMRC has the resources and the expertise to pursue tax disputes aggressively. A solicitor who understands tax law levels the playing field — and ensures the taxpayer's position is presented as compellingly as possible.

A solicitor will advise on the merits of HMRC's position, respond strategically to all HMRC correspondence, negotiate a settlement where appropriate, and represent the taxpayer at the First-tier Tax Tribunal or the Upper Tribunal where a hearing is necessary.

Submit Your Request
1

Tell us about the HMRC dispute

Describe the tax involved, the nature of the dispute — investigation, assessment, penalty, or tribunal appeal — and how far it has progressed.

2

Solicitor assesses the merits and advises on strategy

A tax dispute solicitor reviews the HMRC position, assesses the strength of the taxpayer's case, and advises on the most cost-effective route to resolution — negotiation or tribunal.

3

Free initial consultation

You receive clear advice on the HMRC dispute and the best legal approach — at no cost and no obligation.

Free Initial Consultation

An HMRC dispute that is not handled correctly from the outset becomes more expensive to resolve — both in tax and in penalties. Early specialist legal advice makes the difference.

Get specialist tax dispute advice from a solicitor who understands HMRC's approach and how to challenge it effectively — free initial consultation, no obligation.

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Common Questions

Tax and HMRC disputes — what people ask us.

HMRC has opened an enquiry into my tax return. What should I do?

Do not respond to HMRC without taking legal advice first. The information you provide in response to an enquiry can be used against you — either in the current enquiry or in a subsequent investigation. A solicitor will review the enquiry notice, assess the scope of the enquiry, advise on what information is required to be provided and what is not, and manage the response to HMRC. In some cases, the enquiry can be closed quickly with the right response; in others, it develops into a fuller investigation that requires sustained legal management. Early involvement of a solicitor significantly improves the outcome of HMRC enquiries.

HMRC has raised a tax assessment against me. Can I appeal?

Yes — most HMRC assessments can be appealed, initially by a statutory review within HMRC, and thereafter to the First-tier Tax Tribunal. The appeal must be notified to HMRC within 30 days of the assessment (or the review conclusion). A solicitor will assess whether the assessment is correct, prepare grounds of appeal, and represent the taxpayer at the tribunal where the appeal proceeds to a hearing. Where the assessment arises from an HMRC enquiry, a solicitor will also advise on whether the enquiry was conducted in accordance with HMRC's Code of Practice and whether any procedural failings by HMRC affect the validity of the assessment.

What is the difference between a Code of Practice 8 and a Code of Practice 9 investigation?

A Code of Practice 8 (COP 8) investigation is HMRC's civil investigation of serious suspected tax fraud or avoidance — typically into the tax affairs of individuals or businesses where HMRC believes there is a significant tax loss but has not yet decided whether fraud is involved. A Code of Practice 9 (COP 9) investigation is HMRC's most serious civil investigation — conducted where HMRC has formed a reasonable suspicion of fraud. Under COP 9, the taxpayer is offered the Contractual Disclosure Facility (CDF) — an opportunity to disclose all tax fraud in exchange for a promise that HMRC will not pursue criminal prosecution. Rejecting the CDF or making an incomplete disclosure can result in criminal prosecution. A solicitor is essential in managing both COP 8 and COP 9 investigations from the outset.

Can I appeal an HMRC penalty for a late tax return?

Yes — HMRC late filing, late payment, and inaccuracy penalties can all be appealed. For late filing and payment penalties, the most common ground of appeal is "reasonable excuse" — a genuinely unforeseeable or unavoidable reason why the return was not filed or the tax not paid on time. HMRC's standard list of acceptable excuses includes serious illness, bereavement of a close relative, and postal or IT system failures. A solicitor will assess whether the facts support a reasonable excuse argument, submit the appeal, and represent the taxpayer at the First-tier Tribunal where HMRC refuses to accept the excuse. Special reduction of penalties (where exceptional circumstances apply) can also be pursued on appeal.

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