HMRC Enquiries & Compliance Checks
HMRC may open a compliance check where it wishes to verify the accuracy of a tax return or understand a
particular tax position. These enquiries can arise from routine risk assessment, third-party
information, disclosure campaigns or specific technical issues.
We provide representation throughout the enquiry process, including:
- Corporation Tax enquiries
- Self Assessment enquiries
- VAT compliance checks
- Employer compliance reviews
- R&D tax relief compliance checks
- Capital allowance enquiries
- HMRC information requests
We review the technical issues raised, prepare responses to HMRC and support clients throughout the
enquiry until the matter is concluded.
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HMRC Information Notices
Where HMRC issues a formal information notice, it is important to understand both your obligations and
your rights.
We advise clients on responding to information requests, reviewing the scope of notices issued under
Schedule 36 Finance Act 2008 and preparing appropriate responses supported by relevant documentation.
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Tax Appeals & Penalty Reviews
If you disagree with an HMRC decision, you may have statutory rights of appeal.
We advise on:
- Late filing penalties
- Late payment penalties
- Inaccuracy penalties
- Reasonable excuse claims
- Statutory Reviews
- Alternative Dispute Resolution (ADR), where appropriate
- Appeals against HMRC decisions
Where appropriate, we prepare technical representations supported by legislation, HMRC guidance and
relevant case law.
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Voluntary Disclosures
Where historic tax errors are identified, voluntary disclosure can often provide a structured route to
correcting matters before HMRC takes further action.
We assist businesses and individuals in reviewing historic tax positions, quantifying any adjustments
required and preparing disclosures in accordance with HMRC procedures.
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Technical Tax Disputes
Not every dispute concerns whether tax is due. Many arise because of differing interpretations of tax
legislation or the application of reliefs.
We advise on disputes involving:
- Corporation Tax
- Capital Allowances
- Research & Development (RDEC)
- Transfer Pricing
- Corporate Interest Restriction (CIR)
- Patent Box
- Share schemes and employment-related securities
- Business restructures
- Residence and permanent establishment issues
Where specialist technical analysis is required, we work with clients and their existing advisers to
present well-supported tax positions.
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Why Choose Us
Tax disputes require more than routine compliance.
Our practice focuses on the technical aspects of UK taxation, helping clients navigate HMRC enquiries
through careful analysis, clear communication and practical advice.
We understand that an HMRC enquiry can disrupt your business and create uncertainty. Our role is to
explain the issues, manage correspondence with HMRC and help you reach an informed resolution based on
the facts and the applicable legislation.
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