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Tax & HMRC Disputes

Tax & HMRC Dispute Solicitors — Investigations, Assessments, Appeals, and Tribunal Representation

HMRC investigations, tax assessments, and penalty notices create serious legal and financial risk for individuals, company directors, and businesses of all sizes. A specialist tax dispute solicitor advises from the moment of the first HMRC contact — through enquiry, investigation, internal review, and appeal to the Tax Tribunal — protecting your legal rights and limiting your financial exposure at every stage. Acting before responding to HMRC is the single most important step a taxpayer can take.

HMRC investigations (COP8 & COP9) VAT & PAYE disputes Tax tribunal representation Penalty & assessment appeals
⚠️ Every communication with HMRC during an investigation is on the record — and what you say matters. A poorly drafted response, an inadvertent admission, or providing documents beyond those legally required can significantly worsen your legal and financial position. Take specialist legal advice before responding to any HMRC enquiry, compliance check, information notice, or Code of Practice letter.

Tax & HMRC Dispute Services

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HMRC Tax Investigations

COP8 and COP9 fraud investigations, Contractual Disclosure Facility, voluntary disclosures, HMRC information powers, and dawn raid advice.

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VAT Disputes

VAT assessments, input tax recovery disputes, partial exemption, option to tax, MTIC fraud allegations, and VAT tribunal appeals.

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PAYE & Employer Compliance

IR35 and off-payroll working disputes, Loan Charge challenges, disguised remuneration, PAYE compliance checks, and employment status.

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Self-Assessment Disputes

HMRC enquiries (aspect and full), discovery assessments, closure notices, information notices, and return amendment advice.

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Capital Gains Tax Disputes

HMRC valuation challenges, principal private residence relief disputes, Business Asset Disposal Relief challenges, and SDLT disputes.

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Corporation Tax Disputes

R&D tax credit disputes, transfer pricing challenges, GAAR investigations, group relief disputes, and corporation tax enquiries.

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Inheritance Tax Disputes

HMRC challenges to BPR and APR claims, gifts with reservation of benefit, estate valuation disputes, and IHT assessments.

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Tax Tribunal Appeals

First-tier Tribunal (Tax Chamber), Upper Tribunal representation, statutory review, and HMRC Alternative Dispute Resolution (ADR).

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HMRC Penalty Appeals

Inaccuracy penalties, failure to notify penalties, late filing penalties, reasonable excuse defence, special reduction, and penalty suspension.

How a Tax Dispute Progresses

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HMRC contact — enquiry or compliance check — most tax disputes begin with a letter from HMRC: an enquiry notice under TMA 1970 s.9A (self-assessment); a VAT compliance check; a PAYE employer compliance review; or a Code of Practice letter (COP8 — suspected serious fraud without CDF offer; COP9 — HMRC's most serious civil investigation, offering the Contractual Disclosure Facility). A solicitor advises on what HMRC is legally entitled to receive, the scope of your obligations, and how to respond in a way that limits further investigation.
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Information and document requests — FA 2008 Schedule 36 — HMRC has statutory information powers: information notices (to the taxpayer), third-party notices (to banks, accountants, and customers), and inspection powers. Compliance is mandatory in most cases, but the scope of the obligation and the rights to appeal certain notices are important. A solicitor identifies which requests are legally enforceable, challenges disproportionate demands, and manages the production of documents to minimise further exposure — including protecting legally privileged material.
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HMRC assessment — tax, penalty, or both — where HMRC believes tax is unpaid, it raises an assessment: a VAT assessment (VATA 1994 s.73), a discovery assessment for income tax or CGT (TMA 1970 s.29), or a penalty notice (FA 2007 Sch 24 for inaccuracies; FA 2008 Sch 41 for failure to notify; FA 2009 Sch 55 for late filing). A solicitor analyses whether the assessment has been correctly raised within time limits, on a proper legal basis, and at the correct amount — and prepares detailed grounds of appeal.
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Statutory review and HMRC ADR — before the Tribunal — before appealing to the Tax Tribunal, a taxpayer may request an HMRC statutory review (30 days to request; HMRC has 45 days to respond — TMA 1970 ss.49B-49D) or HMRC Alternative Dispute Resolution (a facilitated meeting with an HMRC mediator). A solicitor assesses whether review or ADR is likely to be productive, prepares the review request or ADR position statement, and represents the taxpayer throughout — retaining the right to appeal to the Tribunal if the dispute is not resolved.

Frequently Asked Questions

How long does an HMRC investigation take?

An aspect enquiry into one or two points typically resolves within 6–12 months. A full enquiry covering the entire return commonly takes 12–24 months. A Code of Practice 9 (COP9) fraud investigation can take 2–4 years or more. A VAT compliance check or PAYE compliance review typically resolves in 3–6 months. A solicitor manages the process throughout — keeping the investigation targeted and minimising both its duration and your financial exposure.

Do I need a solicitor or an accountant for an HMRC dispute?

An accountant is well-suited to a routine enquiry into accounting figures or a straightforward self-assessment dispute. A solicitor is essential where: the investigation involves potential fraud (COP8 or COP9); HMRC alleges deliberate conduct (triggering higher penalties); there is any risk of criminal prosecution; HMRC seeks information beyond its legal powers; the dispute is heading to the Tax Tribunal; or the financial exposure is substantial. Most importantly: only a solicitor's advice is protected by legal professional privilege — HMRC cannot compel disclosure of solicitor-client communications under FA 2008 Sch 36 para 23. Accountant communications have no such protection.

Can I go to prison for a tax dispute?

HMRC has power to prosecute for criminal tax evasion — under TMA 1970 s.106A (fraudulent evasion of income tax), Finance Act 2000 s.72 (fraudulent evasion of VAT), the Fraud Act 2006, and the Proceeds of Crime Act 2002. In practice, HMRC prosecutes a small number of cases annually and generally prefers a civil investigation of fraud (COP9) to a criminal prosecution. The risk of prosecution increases significantly where conduct is deliberate, the amount involved is large, or there has been active deception. A solicitor advises on the criminal risk and on the appropriate response from the outset.

What is the time limit for HMRC to open an enquiry into my tax return?

HMRC has 12 months from the filing date to open an enquiry under TMA 1970 s.9A (the "enquiry window"). After the enquiry window closes, HMRC can only raise a discovery assessment (TMA 1970 s.29) if a loss of tax has been discovered that the officer could not have been expected to be aware of from the information in the return. Discovery assessments are subject to further time limits: 4 years for non-deliberate underassessment; 6 years for careless conduct; 20 years for deliberate conduct or offshore non-compliance.

What is legal professional privilege and why does it matter in an HMRC investigation?

Legal professional privilege (LPP) protects confidential communications between a solicitor and client made for the purpose of giving or receiving legal advice (advice privilege) or in connection with litigation that is reasonably contemplated (litigation privilege). HMRC cannot compel disclosure of LPP-protected documents or communications under its Schedule 36 information powers (FA 2008 Sch 36 para 23). Communications with an accountant on tax matters are not protected by LPP — only communications with a solicitor are. Instructing a solicitor from the outset of an investigation ensures that your legal advice is privileged and that HMRC cannot demand access to it.

How It Works

One clear request. A tax dispute solicitor protects you from the first HMRC letter to the Tribunal.

No upfront cost. A specialist tax dispute solicitor advises on your legal obligations, manages HMRC communications under privilege, challenges assessments and penalties, and — where necessary — represents you before the First-tier Tribunal (Tax Chamber) and beyond.

Submit Your Request
1

Tell us about the HMRC matter

Describe the HMRC communication, the tax involved, the amounts at stake, and any response deadline you have been given.

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Matched to a specialist

We connect you with a specialist tax dispute solicitor experienced in your specific type of HMRC matter.

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Dispute resolved

Your solicitor manages all HMRC communications under privilege, challenges the assessment or penalty, and — if necessary — appeals to the Tax Tribunal.

Tax & HMRC Disputes

HMRC investigations and assessments carry serious legal and financial risk. A specialist solicitor limits that risk.

From the first HMRC enquiry through to Tax Tribunal representation — a specialist tax dispute solicitor manages every stage of the dispute, protects your rights under legal professional privilege, and achieves the best possible outcome for your tax position.

Submit Your Request

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