Have you reached an impasse with HMRC?

Alternative Dispute Resolution is one of the way to try and resolve a dispute with HMRC. Our Director, Lora Witt, is a certified civil and commercial mediator with a wealth of experience in negotiations and ADR with HMRC.

How ADR works

An HMRC mediator who has been trained in mediation skills and techniques will work with you (or with us, if we are representing you) and the HMRC officer dealing with your case. They will help you both explore ways to resolve your dispute, including helping you focus on the areas that need to be resolved and re-establish communications, if needed.

What ADR can be used for

ADR can be used before and after HMRC has issued a decision that can be appealed against, and at any stage of an enquiry, including:

• during a compliance check when you are unable to reach an agreement with HMRC, or where progress in the enquiry has stalled;
• at the end of a compliance check, when a decision has been made that you can appeal against.

ADR does not affect your right to appeal, or to ask for a statutory review.

Each application is considered on a case by case basis. ADR is not a statutory process and HMRC reserves the right to reject applications that they do not consider appropriate for ADR.

ADR can be used when:

• communications have broken down between you and HMRC
• there are disputes about the facts
• a dispute appears to be a result of a misunderstanding
• you want to know why HMRC has not agreed evidence you have given them and why they want to use other evidence
• you are not clear what information HMRC has used and you think they may have made wrong assumptions
• HMRC need to explain why they need more information from you

You cannot use ADR for:

• complaints and disputes about HMRC delays in using information or giving you misleading advice 
• debt recovery or payment issues 
• disputes about tax credits 
• disputes over default surcharges
• automatic late payment or late filing penalties
• PAYE coding notices
• Extra-Statutory Concessions
• cases that HMRC’s criminal investigators are dealing with
• pension liberation schemes
• High Income Child Benefit Charges
• disputes about the National Minimum Wage
• accelerated payments and follower notices
• cases the First Tier Tax Tribunal have categorised as ‘paper’ or ‘basic’

When you can apply

You can apply for ADR at any stage of an enquiry and at any stage of the tribunal proceedings.

How we can help

If you think that in impasse with HMRC has been reached and you cannot come to an agreement, or if you feel that your appeal may not succeed and you wish to negotiate the HMRC decision, we can review your case and discuss with you best course of action. ADR may be one of the options. Contact us for a free no obligation consultation today. 

We can help you deal with any tax investigation through expert advice and specialist representation. Our team deals with matters ranging from individual tax disputes to large and complex multiple client cases. 

• Formal and Informal Notices
• Compliance Checks
• Penalty Notices
• Discovery Assessments
• Voluntary Disclosures to HMRC
• Accelerated Payment Notices (APNs)
• Code of Practice 8 – CoP 8 Investigations
• Code of Practice 9 – CoP 9 Investigations
• Contractor Loan Schemes and the Loan Charge
• DOTAS/POTAS Inquiries
• PAYE Tax Investigations 

• Corporation Tax Investigations
• IR35 Disputes
• VAT Investigations and Inspections
• HMRC Unannounced Inspections and Visits
• Settlements with HMRC
• Time to Pay Arrangements
• Statutory Reviews
• Forensic Tax Advice
• Tax Litigation Advice
• Corporate Advisory
• Private Client Advisory