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.


Accelerated Payment Notices

Many businesses and individuals are facing financial hardship as a result of APNs. We can help you achieve the best possible outcome.


Tax fraud investigations

Tax fraud investigations are undertaken under Code of Practice 9 (COP9). We can provide the sensitive handling, which these cases require.


Information requests

DSW offer extensive experience in challenging HMRCs increasingly aggressive approach and in negotiating on penalties and interest.


Discovery notices

‘Discovery notice’ powers enable HMRC to investigate issues from years ago. We have been very successful in challenging such notices.


Disclosing liabilities 

HMRC regularly offers opportunities for taxpayers to disclose their liabilities and bring their affairs up to date. We can advise on the best strategy.


High Risk Corporates

HMRC’s High Risk Corporates Programmes target big business. We have rare experience of working both for both sides and offer an ‘all in one fee’.


Avoiding penalties

DSW can help ensure that any penalties are not applied inappropriately. If you receive a penalty, or a threat of penalty, contact us immediately.


Alternative Dispute Resolution

The DSW Tax Resolution team have experience of using ADR to help bring enquiries to a speedy and satisfactory conclusion.

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 have extensive experience of negotiating Time to Pay (“TTP”) arrangements. These agreements can range in length from a couple of months to numerous years. Furthermore, they provide certainty along with much needed financial breathing space to our clients.

We ease the pressure upon yourselves by speaking to HMRC on your behalf and produce an achievable and agreed proposed payment plan based on your cash flow status. 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.

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. Without such assurance, HMRC will refuse the request for Time to Pay.

Advantages of TTP

  • Payments spread out over time improving cash flow position,
  • All legal/enforcement action procedures are halted.
  • No penalties or surcharges are applied whilst agreed payments are met.
  • CT,VAT and PAYE can all be included within the agreement.

Key Guidelines

  • HMRC must receive a proposal specifying time requested and affordability.
  • TTP is only agreed if HMRC agree that you are unable to meet the original tax due date.
  • If the financial situation changes, HMRC must be informed immediately.
  • HMRC expect the time to pay to be over the shortest length of time possible. It is a process to assist in times of financial difficulty, it is not an automatically provided option.

Early contact with HMRC will strengthen any proposal so, to enable us to secure the best possible agreement with HMRC it is advisable to contact us as soon as possible.