Tax Disputes Solicitors

Our tax disputes solicitors act for SMEs and high-net-worth individuals facing HMRC investigations

Tax Disputes Solicitors

An HMRC investigation does not stay contained for long. What starts as a routine enquiry into a single tax return can expand into a full tax investigation of your personal or business finances,  with significant penalties and reputational exposure.

Based in London, our partner-led tax disputes lawyers act for SMEs and high-net-worth individuals at every stage of the process. For a free consultation, call our tax disputes solicitors today on 020 7467 3980.

Our HMRC tax disputes and investigation services

We regularly advise our clients on proceedings at Tax Tribunal including in appeals to the First-tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax and Chancery Chamber):

  • Income tax disputes 
  • Corporation tax disputes
  • Capital Gains Tax disputes
  • VAT disputes

Where a tax dispute has a commercial or insolvency dimension, our litigation team handles the full picture, specialising in all taxes for individuals and owner managed businesses including:

When does a tax dispute become tax litigation?

Most HMRC disputes are resolved without ever reaching a tribunal. When they are not, tax litigation begins and the rules of engagement change significantly.

When a tax investigation reaches an impasse

When HMRC issues a formal decision and refuses to accept your position, you face a choice: accept the closure notice and pay what is demanded, or appeal.

Appealing means committing to a formal legal process with real costs and procedural obligations on both sides. That decision should always be preceded by an honest assessment of the case’s strength and whether the amount in dispute justifies proceeding.

How is a HMRC dispute different from a commercial dispute?

Tax disputes against HMRC are not like pursuing a claim against another business. HMRC operates with powers and advantages no commercial opponent holds.

  • Statutory powers: HMRC can issue information notices, obtain third-party bank data, and in some cases recover tax directly from bank accounts
  • The burden of proof: in most tax appeals, the burden falls on the taxpayer. HMRC’s assessment stands unless you can show otherwise
  • A specialist tribunal system: tax appeals are heard in the First-tier Tribunal (Tax Chamber), a specialist forum with its own procedural rules that requires specific expertise to navigate effectively
  • An institutional opponent: HMRC has dedicated in-house legal teams and counsel. Entering tribunal proceedings without specialist legal representation places the taxpayer at an immediate disadvantage.

Can you dispute a HMRC tax assessment or penalty?

Yes. HMRC’s decisions are not final. Most can be challenged, either through an internal review or a formal appeal to the Tax Tribunal.

How do you dispute an HMRC tax assessment?

When HMRC issues a tax assessment or closure notice, you have 30 days to appeal. Missing that deadline is the most common and costly mistake taxpayers make.

Within that window, you can request an HMRC statutory review — an internal review by an independent officer that takes up to 45 days and can uphold, vary, or cancel the assessment. It is not binding, and in cases where the legal position is clear or the amount significant, proceeding directly to tribunal is often the stronger option.

How do you dispute a HMRC tax penalty?

HMRC penalties can be challenged on the grounds of reasonable excuse, special circumstances, or proportionality. What constitutes a reasonable excuse is defined by case law, not HMRC guidance, and HMRC’s own interpretation of the test is frequently too narrow.

Reasons to instruct Summit Law

HMRC tax disputes move fast and the decisions made early in the process directly affect the outcome. Our partner-led team has a deep understanding of HMRC procedures and fights rigorously for the best possible result.

  • Partner-led advice: your matter is handled by senior tax dispute solicitors 
  • Litigation expertise: we bring insolvency litigation experience to tax disputes with a commercial dimension, including cryptocurrency and tax scheme challenges
  • End-to-end experience: we act at every stage of the process, from the first HMRC information notice through to Upper Tribunal proceedings
  • Transparent pricing: fixed fees, retainers, and hourly rates are available. You will know the cost before we start

Contact our tax dispute solicitors today

When HMRC raises an assessment or opens an investigation, the 30-day appeal window closes fast. Summit Law’s partner-led team acts quickly and advises clearly on your options from day one.

To speak with our tax dispute solicitors, simply call 020 7467 3980 today.

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