Each year, HMRC investigates hundreds of thousands of cases involving both individuals and businesses, ranging from simply checking an item on a tax return to a full-scale investigation. Being the subject of a tax enquiry can be highly stressful and the penalties for those found to have breached the rules can be severe.

DSW Tax Resolution has years of experience in handling tax enquiries of all types and negotiating the best available settlement with the tax authorities. The team is led by former tax inspector Philip Manley, who led HMRC’s technical response team for Accelerated Payment Notices, and who has also advised clients while working for a ‘big four’ firm.


High Risk Corporate programmes.

We hold experience of supporting companies resolve complex planning issues and involvement in HMRCs high risk corporate programme. In these HRCP cases, we can provide the resource to successfully negotiate and work through all of the complex enquiries. HRCP is always one of the most time-consuming matters a business may face and its essential therefore to use support of the highest technical level to ensure that the programme can be completed in a timely satisfactory manner.

Enquiries within this programme may head to tribunal, yet we always aim to reach agreement with HMRC through the extensive dispute resolution experience in the DSW team.


Accelerated Payment Notices (APN’s)

Whilst APNS have no formal right of appeal, recipients are able to provide representations against them and there are a number of methods to ensure that the best possible outcome is achieved.

The approach for each recipient will depend upon a number of factors and as such there is a need for each case to receive an individual and bespoke review.
Our team is led by the ex HMRC inspector that dealt with APNs at their beginning and that makes us best placed to undertake representation by providing the following services:


  • Full review of your case to establish the facts while confirming that the Finance Act legislation on APNs was correctly followed and that the APN was validly issued.
  • Analysis of the HMRC calculation to ensure that the amounts claimed by HMRC are correct and that any allowances available have been correctly provided.
  • Drafting of representation if we feel that the APN is either invalid or the amounts incorrect.
  • Examine all options available including negotiating a Time to Pay arrangement with HMRC.


Tax Fraud Investigations

If HMRC believe there has been a loss of tax as a result of fraudulent behaviour then they will open the enquiry under Code of Practice 9 (COP9)

We have successful experience in allowing clients to make a complete disclosure to HMRC of their tax practices admitting or denying that fraud that has taken place. In cases which fraud has taking place disclosures can provide immunity from prosecution. A full disclosure under CDF can also reduce the financial penalties HMRC will seek when negotiating the final settlements.

Our team has experience in attending the meetings with HMRC, agreeing the scope of, and then preparing the COP9 reports on the client’s behalf ultimately achieving the best possible outcome for our clients


Information Requests

HMRC as part of their investigations, ask the taxpayer to provide a large amount of information under Schedule 36 requests, these are often large and extremely time consuming taking our clients away from being able to concentrate on their normal lives.

We therefore negotiate with HMRC where we feel the request is unnecessary and aim to narrow down the enquiry to the specific queries. This reduces the burden on the client. We have also successfully appealed SCH36 notices resulting in their amendment and also complete withdrawal.

We similarly have experience of handling appeals against the notice to the Tax Tribunal. Written notice of appeal must be given to HMRC within 30 days.

If a Tax Tribunal notice has been issued contact us immediately safeguarding as much of the notice period to defend your grounds of appeal.


Discovery Notices

“Discovery’ notices (S29 Taxes Management Act 1970) provide HMRC up to 20 years to make an assessment of tax from when a ‘discovery’ of information that was not ‘made available’ within the normal enquiry window. With our knowledge of past cases and the legislation, we can defend against HMRCs use of these powers to ensure that the taxpayer received the protection and security that the enquiry window is supposed to provide.

If you receive a discovery assessment contact us immediately to ensure that we have time to fully review before any set deadlines.



Penalties can be and often are, applied by HMRC in most types of enquiries. These penalties can in theory be for as much as 100% of the potential tax loss. Although penalties can be appealed and if HMRC accept that you have a ‘reasonable excuse’ then the penalty may be amended or cancelled.

We have successful experience of all stages of the appeal process and can assist you both technically and by removing the stress and worry by undertaking these negotiations on your behalf.

There is a strict 30-day deadline for making such an appeal so it is vitally important you contact us as soon as possible to enable us to review the case in full and make the appeal on your behalf.


Alternative Dispute Resolution.

Historically, many HMRC enquiries have dragged on for months and sometimes years. In an effort to combat this, We have worked closely with the Alternative Dispute Resolution to bring long standing cases to closure saving valuable time and costs for our clients.

If you feel your enquiry has taken up too much time and wish to try this alternative approach, please contact us and we can explain the next steps and whether ADR is suitable for you.


Disclosing Liabilities

HMRC often offer the opportunity for taxpayers to make disclosures rather than go through a lengthy enquiry process. These opportunities often include the guarantee that no penalties or litigation will be applied at a later date. An example is the current Contractor Loan Settlement scheme, where clients who have received ‘loans’ which HMRC now consider to be income, can disclose these and in return gain peace of mind and finality rather than having to await the 2019 Loan Charge.

In many cases there is a financial benefit to settling early, along with achieving the finality. If there are any discrepancies with HMRCs figures or any areas of doubt exist we undertake the required communication on your behalf.

We can assist through this process by ensuring the settlement deeds are offered with figures that are correct.


Time to Pay – HMRC

Many businesses at times find themselves, for varying reasons, with cash flow difficulties. Tax Liabilities due to HMRC can often be large, with late or non-payment bringing severe penalties.

DSW Tax Resolution has extensive experience of negotiating Time to Pay (“TTP”) arrangements. These agreements can range in length from a couple of months to numerous years. Our proposals contain all the information required by HMRC to enable them to recognise the need for the payment plan, whilst reassuring them that as well as settling historic issues, no future liabilities will arise.

We have extensive contacts within HMRC and have worked closely with their Debt Management and Banking team to successfully agree numerous cases in the past. Through the process we ease the pressure upon on our clients by speaking to HMRC on your behalf and produce an achievable payment plan based on your cash flow status giving certainty, financial breathing space and closure

Tax Resolution