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For Solicitors

The tax specialists behind the legal team

Law firms come to us when a matter turns on tax and HMRC's behaviour: a criminal defence client who has also received a COP9 letter, a director facing a personal liability notice inside an insolvency, a divorce where one party's declared income doesn't match their lifestyle, a statutory demand built on a disputed assessment. We do the tax forensics and the HMRC-facing strategy; you conduct the litigation and keep the client. We are not solicitors and we do not give legal advice, which is precisely why the division of labour works cleanly.

What we do for law firms

COP9 and Contractual Disclosure Facility management run in parallel with criminal defence instructions, so the disclosure protects rather than incriminates. Challenges to the tax foundation of statutory demands, bankruptcy petitions and winding-up petitions, where the underlying assessment, not the insolvency procedure, is the real battleground. Personal liability notice and security notice defence for directors. Quantum and behaviour analysis in penalty disputes, including deliberate-conduct findings that your client says are wrong. Reconstruction of income and takings from bank, card-acquirer and third-party data in matrimonial, POCA and confiscation matters. First-tier Tribunal appeals: grounds, evidence, witness statements and skeleton support. Judicial review pre-action groundwork where HMRC has fettered a discretion or ignored its own guidance.

When to pick up the phone

Before your client responds to a COP9 letter or attends any HMRC interview. The opening position is the case. When HMRC serves a Schedule 36 notice on your firm or your client and privilege needs asserting properly rather than loudly. When an insolvency practitioner or petitioning creditor is relying on an HMRC debt your client disputes: the assessment can often be attacked even where the procedural clock looks spent, and late-appeal permission under Martland is more available than most assume. And in any proceedings where the other side's tax narrative is doing quiet work. We read the HMRC file the way its authors intended it.

How we work with you

Instruct us as consultants to your firm and our work product goes to you, not the lay client, useful where you want our analysis inside the umbrella of your client's litigation privilege (a solicitor's instruction is a materially better home for sensitive analysis than an accountant's file, which HMRC can reach with a Schedule 36 notice). We produce written reports suitable for exhibiting or for counsel, attend conferences, and prepare cross-examination material on HMRC methodology. Where you would rather simply refer the tax dispute out and stay on the legal matter, that works too. We keep you copied throughout and the client remains yours.

Why firms use us

Some of our team trained and worked inside HMRC. We know how an investigation file is built, what the inspector's internal guidance actually says, where best-judgement assessments are soft, and when a "final" position is nothing of the sort. Fees are fixed and agreed per stage before work starts, so you can put a clean number in your client care letter. We are available 8am–10pm, seven days a week, and we work nationally, most HMRC work is done by correspondence, phone and video in any event.

Questions firms ask us

Will you deal directly with our client?

Only if you want us to. Consultancy instructions where we report solely to the firm are common, particularly in criminal and matrimonial matters.

Can you give evidence?

We prepare analysis and reports for use in proceedings and can support counsel on HMRC methodology and quantum. Where a formally instructed expert is needed, we will say so and help you frame the instruction.

Our client's paperwork is chaotic. Is that fatal?

No. It is normal. Most investigation work is reconstruction from bank data, merchant statements and third-party records. We would rather see the true state of the records early.

What does it cost?

The first discussion is free and without obligation. After that, a fixed fee per defined stage, quoted in advance. No percentage arrangements, no referral commissions in either direction.

Free technical library

Our professional guides cover the ground your matters actually turn on: legal professional privilege in HMRC investigations, the civil–criminal boundary, Schedule 36 information powers, discovery time limits, the Schedule 24 penalty framework and late appeals under Martland. Free, uncluttered, written for professionals.

A matter with a tax problem inside it? Outline it in two minutes. We will tell you the same day, without charge, whether it needs us.

LONDON: 020 3827 1447  ·  DERBY: 01332 308655  ·  info@taxdisputeconsultants.co.uk

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