We have significant experience in achieving the most effective resolution at minimum cost and concern to the client when dealing with HMRC disputes.

We are skilled in negotiating with HMRC and may be able to bring the matter to a close without the matter going to the Tax Tribunal.

We have also gained a reputation for our ability to resolve technically complex cases, so much so that we have been asked to take over a number of complex cases from other advisers. We pride ourselves in our meticulous extraction of the core issues. Single facts and nuances the client may not consider important may, in fact, have a significant impact on interpreting actions and applying the law.

Therefore, whether a case needs taking over or a fresh case is yet to begin, we will invest the time and effort to acquire an intimate knowledge of all the facts surrounding the case.  It is only through this process that we are able to offer bespoke and targeted advice tailored to the specific client’s needs, which we are confident will achieve an effective resolution.

Often, using our experience of such cases, we will identify an alternate, more pertinent reasoning and then by utilising the appropriate evidence we are able to successfully resolve the investigation.

Our extensive experience and technical knowledge gives us the confidence to proceed to litigation in an investigation case, where settlement is not the most effective solution for the client.

With HMRC’s increasing powers, recent modifications in policy and the application of the litigation strategy we have embraced the ability to instruct in the tax tribunals. This gives us first-hand awareness and appreciation of both HMRC’s and the courts’ approach and policy and allows us to provide an all-inclusive service in order to deliver the best outcome to our clients.

By providing an all-inclusive service we work collaboratively with Tax Counsel, and when required with legal teams, to take appeals through all the courts.

Appealing a decision of HMRC

In the first instance taxpayers must send a notice of appeal to HMRC in writing within 30 days of the date of HMRC’s decision. In relation to VAT, the appeal is made direct to the Tribunal.

The procedure is different for VAT because HMRC is obliged to offer an internal review in relation to VAT, whereas it can choose to offer a review in relation to other taxes (although it normally does).

In relation to direct taxes the taxpayer can request an independent review when or at any time after sending an appeal to HMRC.

Independent Review

If a taxpayer disagrees with a HMRC decision, they can usually appeal the decision. The procedure for doing so depends upon whether the appeal relates to direct taxes or to VAT.

HMRC must take account of any representations made by the taxpayer as part of that review. This could be the perfect time to obtain a second opinion from our tax litigation specialist at Lancaster Knox. A fresh pair of eyes and a different approach often help extract pertinent points which may have been overlooked during the investigation to achieve an effective resolution.

The First-tier Tribunal

Tax Tribunals are more formal and ‘legalistic’ than those that most taxpayers (or their advisers) will have previously experienced, with greater requirements placed on the submission and presentation of evidence and strict time deadlines that must be met

Trying to handle an appeal or prepare representations for a case review can be extremely difficult and specialist advice is invaluable to guide you through the process.


At Lancaster Knox, our Tax Investigation specialists are industry recognised and we are adept at managing interactions with HMRC to ensure that the process runs smoothly and that the client’s interests are best protected.

We are constantly dealing with HMRC officers and the specialist Advocacy units so we have up-to-date insights into current HMRC practice and policy.  This means we can provide pragmatic advice blended with leading industry technical and strategic expertise to achieve the most effective resolution for our clients.

If agreement cannot be reached with HMRC, we provide our clients with realistic advice regarding the likely chances of success of any appeal and the potential costs involved so a comprehensive decision can be made.