Tax Dispute Resolution

When you and HMRC disagree — about an assessment, an enquiry conclusion, a penalty or a ruling — this is the discipline of getting to the right answer at the lowest cost: negotiation, mediation, statutory review and, where necessary, appeal.

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Most tax disputes are lost through process rather than merits: deadlines missed while deciding what to think, positions conceded in friendly phone calls, appeals filed late or aimed at the wrong target. HMRC's machinery — assessments, reviews, tribunals — runs on fixed clocks, and it is operated by people who use it daily against taxpayers who are seeing it for the first time.

Acumon levels that asymmetry. Several of our advisors ran disputes from HMRC's side; now they run them from yours — managing the procedure, building the evidence, and choosing the route (settlement, ADR, review, tribunal) that resolves your dispute fastest at the best defensible outcome.

Disputes We Take On

The full range of disagreement with HMRC: enquiry conclusions you dispute, discovery assessments reaching into earlier years, penalty determinations and their 'behaviour' labels — careless versus deliberate matters enormously — VAT assessments and security demands, status and IR35 determinations, information notices that overreach, and disputes inherited mid-fight from previous advisors. If HMRC has already opened an enquiry and you simply need it handled, our tax investigation service runs that; dispute resolution is for when the two sides have reached different answers.

Settlement and Negotiation First

Litigation is the most expensive way to resolve a tax dispute, and usually the slowest. The first move is building the technical position properly — evidence assembled, law applied, weaknesses acknowledged internally — and then negotiating with HMRC from that footing, because caseworkers settle defensible cases and dig in against bluster. A position paper that would survive tribunal is, paradoxically, the thing most likely to make tribunal unnecessary.

ADR, Statutory Review and Appeals

Between negotiation and tribunal sit two underused mechanisms. Alternative dispute resolution puts an HMRC-trained mediator between the parties and resolves a substantial share of suitable cases within months — costing little and preserving every appeal right. The statutory review offers an independent second look inside HMRC within fixed time limits, and materially changes or cancels a meaningful share of decisions. Where these fail, we prepare and manage tribunal appeals with specialist counsel instructed as needed — and the earlier stages will have built the case the tribunal sees.

Penalties, Time to Pay and Closing Well

The tax is often only half the dispute; penalties and interest are the other half, and they are negotiable on their own axes — behaviour classifications challenged, reductions for disclosure quality maximised, suspension of careless-error penalties secured where conditions can be constructed, and reasonable-excuse arguments made properly. Resolution also means paying: we negotiate time-to-pay arrangements that survive contact with reality, and close disputes with certainty — no loose years, no unresolved penalty tail.

What You Get With Acumon

Disputed enquiry conclusions, assessments and discovery challenges
Penalty disputes: behaviour classification, reductions and suspension
Alternative dispute resolution (ADR) applications and representation
Statutory reviews invoked and argued within the fixed time limits
First-tier Tribunal appeals prepared and managed, with counsel as needed
VAT assessments, IR35 determinations and information notices contested
Time-to-pay arrangements negotiated as part of final settlement
Ex-HMRC advisors who know how the other side evaluates a case

Why Acumon for Tax Dispute Resolution?

Many of the firm's qualified tax advisors previously worked for HMRC
In-house Chartered Tax Advisor (CTA), qualified by the Chartered Institute of Taxation
All 90 of the firm's professionals are based in the UK
Dedicated HMRC tax investigation service in-house for enquiry-stage work
Case study result: reduced HMRC's and the client's initial estimated payroll liabilities by over 80%

Get a Fixed-Fee Quote

Tell us what you need and we'll come back within one business day with a clear scope and a fixed price — no hourly-rate surprises. Call 020 8567 3451 or use the form and we'll be in touch.

Common Questions

Frequently Asked Questions

How long do I have to challenge an HMRC decision?

For most direct tax decisions, 30 days — to appeal, and to accept or reject an offered statutory review; VAT runs on its own similar clock. Miss the window and you are into late-appeal applications that HMRC can, and does, oppose. The 30 days are for lodging the challenge, not winning it, so the correct move on receiving any decision you dispute is to protect the deadline immediately and argue the substance afterwards. If a deadline has already passed, call us anyway — late appeals succeed with the right grounds, but the clock is now against you.

Is ADR worth trying, or is it a delay tactic?

It is genuinely worth trying in the right cases — and HMRC's own figures consistently show a substantial majority of ADR cases resolving. It works best where the dispute involves facts, valuation or communication breakdown rather than a pure point of law HMRC needs decided publicly. It is quick by dispute standards, cheap relative to litigation, and costs you nothing in rights: appeal positions are preserved throughout. We assess suitability honestly — including telling you when your case is one ADR will not fix.

Do I have to pay the disputed tax while we fight?

It depends on the tax. For direct taxes, payment of the disputed amount can generally be postponed by application while the appeal runs — though interest accrues if you lose. For VAT, the default runs the other way: disputed tax must typically be paid or a hardship application made before appeal proceeds. Accelerated payment notices, where they apply, remove postponement entirely. We deal with the cashflow mechanics at the outset, because a dispute you cannot afford to sustain is a dispute you lose regardless of merits.

My previous accountant handled this and it went badly. Can you take over mid-dispute?

Yes — a significant share of our dispute work arrives exactly this way. We review the file cold: what has been conceded, which deadlines stand, whether the technical position was ever properly made, and what remains recoverable. A fresh review changes outcomes more often than you might expect, because disputes drift when correspondence has been reactive. What we will also do is tell you plainly if the previous advice was right and the position is simply weak — paying us to lose slowly serves no one.

Get in Touch

Ready to Sort Your Tax Dispute Resolution?

Tell us what you need. Within one business day, a qualified accountant will be in touch to talk it through and give you a clear, fixed-fee quote — no obligation.

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