When HMRC asks difficult questions, experience matters.
An enquiry, investigation or dispute is demanding, and in complex cases carries significant financial and wider consequences. We advise from the first information request through to formal dispute, appeal and the Tax Tribunal.
What we handle
From the first letter to the Upper Tribunal
Enquiries and compliance checks
Formal enquiries into returns, information notices and discovery assessments — including whether the assessment is validly made at all.
COP8 and COP9 investigations
Avoidance investigations, and suspected deliberate conduct under the Contractual Disclosure Facility, where the decision taken in the first sixty days matters most.
Nudge letters and disclosures
Offshore accounts, property income, cryptoassets and voluntary disclosures made before HMRC arrives — which is worth real money in penalty terms.
Settlement and ADR
Negotiated settlements, penalty mitigation and alternative dispute resolution where the dispute is about facts or communication rather than law.
Appeals and the Tax Tribunal
Statutory review, appeals, representation before the First-tier Tribunal and coordination with counsel where an onward appeal justifies it.
Historic arrangements
Employee Benefit Trusts, EFRBS, disguised remuneration, accelerated payment notices and the loan charge. The route out is rarely as fixed as the letter implies.
How we work
Strategic and evidence-led. Everything HMRC receives is deliberate.
How a matter is approached from the outset has an important bearing on its direction and eventual outcome. We read the letter for what it actually is — which power, which years, what deadline is running and what HMRC already knows — before anything is answered.
We then establish the underlying facts ourselves, assess HMRC's position, and advise you privately on exposure before a word of it is conceded. Whether an enquiry has just begun or a long-running dispute has reached an advanced stage, you will understand your options at each point.
disputes
Some exposure is best simply accepted
Where the projected liability is modest against the cost and complexity of planning, we say so. That answer is free.
Start with a conversation.
Whether you are considering a transaction, protecting family wealth, dealing with an international matter or facing an HMRC investigation, we can help you understand the position and decide the appropriate next step.