Expert Legal Defence for Tax Dispute and Investigation
At Axis Solicitors, we provide reliable, strategic legal advice to individuals and businesses facing tax disputes or under investigation by HMRC. Whether you’re subject to a compliance check, inquiry, or formal investigation, our experienced solicitors offer expert guidance to protect your interests and resolve issues efficiently.
Expert Tax Dispute Legal Support
At Axis Solicitors, we understand tax disputes and investigations can be highly stressful, disruptive, and financially damaging for individuals and businesses alike.
Our experienced solicitors provide proactive discreet representation throughout every stage of HMRC investigations and disputes.
- Representing clients from initial HMRC enquiries through complex tribunal and litigation proceedings
- Strategic defence focused on minimising penalties protecting finances and safeguarding professional reputations
Comprehensive Tax Dispute And Investigation Services
- Expert support for VAT investigations ensuring accurate lawful responses to HMRC compliance checks
- Representation in HMRC tax investigations including Code of Practice Eight and Code of Practice Nine cases
- Skilled defence in fraud investigations involving false accounting misrepresentation insider trading or dishonest practices
- Guidance through PAYE investigations addressing employer compliance income tax and National Insurance obligations
- Professional representation at First-tier and Upper Tax Tribunals building strong evidence-backed appeals
What Is a Tax Dispute?
A tax dispute arises when HM Revenue & Customs (HMRC) disagrees with the way an individual or business has calculated, reported, or paid their tax liabilities. These disagreements may stem from what HMRC views as under-declared income, excessive deductions or reliefs, late or missing returns, or the use of aggressive tax planning or avoidance schemes.
Tax disputes can be triggered by a variety of events—some as simple as a routine compliance check or discrepancy in a self-assessment tax return, others through whistleblower reports, cross-border data sharing agreements, or risk assessments conducted by HMRC’s sophisticated data analytics systems.
At Axis Solicitors, we understand that such disputes can be deeply stressful, time-consuming, and potentially damaging to your finances, your business, and your reputation. We assist clients in all stages of the dispute process—from early enquiries to formal investigations and appeals—ensuring their rights are protected and a robust legal response is mounted. Whether the issue involves complex offshore structures, employment tax obligations, VAT irregularities, or corporation tax treatment, our solicitors provide clear, strategic guidance every step of the way.
Tax disputes vary widely in scope and severity. They can involve relatively minor queries—such as clarification of a single transaction—or escalate into full-scale investigations covering multiple tax years and business entities. If not managed correctly, what begins as a civil enquiry may develop into a financial problem, particularly where HMRC suspects deliberate dishonesty or fraud.
Early intervention and specialist legal support are essential. A well-constructed response, delivered promptly and professionally, can often resolve issues before they intensify. Our solicitors ensure that your interests are represented fairly, your exposure is minimised, and any potential penalties or charges are rigorously challenged.
Types of Tax Investigations
We represent clients across a wide spectrum of tax investigations, ranging from personal and corporate tax disputes to high-level fraud enquiries and international tax compliance issues. The following are the most common types of HMRC investigations where we provide legal support:
1. Self-Assessment Enquiries
Self-assessment enquiries typically begin when HMRC identifies anomalies or patterns in your personal tax return that warrant further scrutiny. These could include:
- Significant changes in income year-on-year
- Unexplained deductions or reliefs
- Omissions of capital gains or foreign income
- Discrepancies between your tax return and third-party reports (e.g. banks or employers)
These enquiries may be conducted on a random basis or targeted based on risk profiling. While they may initially appear routine, they can rapidly become intrusive and wide-ranging. HMRC may request detailed explanations, supporting documents, and access to bank accounts and business records.
At Axis Solicitors, we prepare and review all correspondence with HMRC, advise on the lawfulness of their requests, and help you provide a consistent, compliant response.
2. Corporation Tax Disputes
Corporation tax disputes affect limited companies and are often centred on how profits are reported, expenses are claimed, and directors or shareholders are remunerated.
- HMRC may also challenge intra-group transactions, transfer pricing arrangements, or the treatment of capital versus revenue expenditure.
Typical triggers for corporation tax enquiries include:
- Large one-off deductions
- Loans to directors
- Research and development (R&D) tax relief claimsErrors in deferred tax calculations
- Use of offshore entities or intercompany charges
Our solicitors work closely with forensic accountants and tax specialists to present a coherent defence. We help businesses justify their accounting practices, defend legitimate reliefs, and negotiate with HMRC on disputed liabilities and penalties.
3. VAT Reviews and Penalties
Value Added Tax (VAT) is an area of high compliance risk, particularly for businesses operating in retail, e-commerce, construction, and import/export sectors. HMRC may initiate a VAT investigation if they detect inconsistencies in returns, excessive refund claims, or signs of non-compliance with registration and invoicing rules.
Common areas of concern include:
- Underreported output VAT
- Overclaimed input tax
- Late registration for VAT
- Errors in EU or international sales reporting
- Improper treatment of zero-rated or exempt supplies
VAT errors can result in penalties of up to 100% of the unpaid tax, along with interest and reputational consequences. HMRC may also investigate suspected fraud, including carousel (MTIC) fraud and missing trader schemes.
We support businesses by reviewing VAT records, identifying risks, correcting errors where necessary, and engaging with HMRC to seek mitigation of penalties under the principles of reasonable care.
4. PAYE and NIC Investigations
Employers are responsible for deducting and paying Pay As You Earn (PAYE) income tax and National Insurance Contributions (NICs) for their staff. HMRC audits employers to ensure full compliance with these obligations, particularly where:
- Staff are incorrectly treated as contractors
- Benefits-in-kind (e.g. cars, accommodation) are not fully reported
- Termination payments are misclassified
- Share schemes or bonuses are not properly taxed
These investigations can result in large retrospective assessments, along with penalties for failure to operate PAYE correctly. HMRC may also investigate National Minimum Wage compliance and employment status under IR35.
Axis Solicitors provides legal support for employers under review, helping you respond to enquiries, resolve disputes over worker status, and avoid penalties through voluntary disclosure or settlement
Living with family or friends may be acceptable, provided there is sufficient space and formal permission is granted.
5. Offshore and International Tax Issues
With the increasing globalisation of finance and robust data sharing between tax authorities under agreements such as the Common Reporting Standard (CRS), HMRC has expanded its focus on offshore income and assets.
Individuals with foreign property, bank accounts, trusts, or income-generating investments may face questions from HMRC, particularly if they have not made a timely disclosure.
Our solicitors advise on the correct use of the Worldwide Disclosure Facility (WDF), defend clients accused of offshore evasion, and handle enquiries involving complex international tax law.
Tax Avoidance and Schemes
Tax avoidance schemes—although not necessarily illegal—are often scrutinised by HMRC. If you’ve used a marketed tax scheme to reduce your liability, HMRC may issue:
- Accelerated Payment Notices (APNs) requiring payment of disputed tax upfront
- Follower Notices obligating taxpayers to concede if a similar case has failed in court
Such notices must be responded to promptly and carefully. We challenge their legality, lodge appeals where appropriate, and advise on strategies for resolving long-running tax planning disputes.
Investigating Authorities and Enforcement Bodies
In the United Kingdom, a number of bodies may be involved in investigating tax disputes and pursuing enforcement:
- HM Revenue & Customs (HMRC): The principal body for tax compliance, civil investigations, and prosecutions.
- Crown Prosecution Service (CPS): Works with HMRC and other agencies in cases where prosecution is pursued.
- Serious Fraud Office (SFO): Handles major fraud and corruption cases, including cross-border tax evasion.
- National Crime Agency (NCA): Investigates organised financial offence and may become involved in money laundering or offshore structures tied to tax evasion.
Powers Of Enforcement Authorities Explained
These bodies are granted significant powers under the Police and Criminal Evidence Act 1984 (PACE), Proceeds of Crime Act 2002 (POCA), and other relevant legislation. Their powers include executing search warrants, seizing digital and physical assets, freezing bank accounts, and compelling individuals to attend interviews under caution.
We advise clients on how to navigate these investigations, challenge the legality of enforcement actions, and protect their constitutional rights throughout the process
1. The Impact Of Tax Investigations
A tax investigation can significantly affect finances, reputation and operations, even when no penalties or criminal charges ultimately arise.
Business Disruption And Pressure
- Lengthy reviews consume management time and divert focus from core operations
- Legal and accounting costs increase significantly during prolonged HMRC investigations
- Commercial transactions delayed causing uncertainty for investors lenders partners
2. Penalties And Surcharges Risk
- Civil penalties imposed for careless deliberate or fraudulent tax behaviour
- Penalties range between fifteen and one hundred percent tax
- Interest charges applied increasing overall financial exposure substantially
3. Reputational Damage Risks
- Investigations strain relationships with clients banks suppliers regulators
- Loss of trust may persist even after clearance
- Professional credibility damaged affecting long-term business opportunities
4. Criminal Liability Exposure
- Fraud suspicions may trigger prosecution under Fraud Act legislation
- Convictions can result in imprisonment fines or director disqualification
- Criminal records severely impact personal and professional futures
5. Asset Freezing Orders
- HMRC may freeze personal or corporate assets under POCA
- Business operations restricted affecting cash flow liquidity independence
- Asset forfeiture risks increase pressure during investigations
6. Increased HMRC Scrutiny
- Future tax returns subject to enhanced HMRC monitoring
- Access to reliefs schemes may become restricted
- Lenders insurers reassess risk profile following investigations
