At Altion Law, we regularly assist clients facing tax disputes and urgent deadlines for a Tribunal appeal. In this case, our client approached us for advice and representation regarding a serious dispute with HMRC over late payment of Capital Gains Tax (CGT). HMRC had issued late filing and payment penalties totalling £20,000, creating significant personal liability.

The client had relied on their accountants for CGT guidance but was never informed about recent legal changes that altered CGT payment deadlines. Unfortunately, the accountants failed to advise on these changes, leading to missed deadlines and HMRC penalties.

With the Tribunal appeal deadline fast approaching, the client was concerned about escalating penalties and urgently needed specialist legal advice. Previous attempts to appeal—both by the accountants and the client—had been unsuccessful. As a last resort, the client contacted Altion Law to see if there was any way to challenge HMRC before paying the £20,000.

Our Approach to HMRC Disputes

We immediately reviewed all documentation, including HMRC penalty notices and correspondence with the accountants. After an initial assessment, we confirmed the client had strong grounds for challenging HMRC penalties. We advised on next steps, including:

  • Drafting a robust HMRC notice of appeal.
  • Providing legal guidance on evidence required to support the client’s case.
  • Advising on strategies to minimize legal costs during the tax dispute process.

Throughout the process, we maintained clear communication, ensuring the client understood each stage of the HMRC dispute and Tribunal appeal.

Outcome: HMRC Penalties Successfully Removed

Our intervention resulted in a successful resolution. HMRC withdrew their appeal, eliminating the £20,000 liability. The entire process took approximately five months, and the client’s legal costs were around £2,200—saving them £17,800 compared to paying HMRC.

Why Timely Action Matters in HMRC Disputes

If you fail to dispute HMRC liabilities within the correct timescales, the debt becomes enforceable. HMRC may escalate matters by visiting your home or business or instructing debt collection agencies. If you receive an HMRC Notice of Enforcement or a letter stating your debt will be passed to enforcement, this is serious. Immediate legal advice is essential.

How Altion Law Can Help

We offer a staged approach to managing tax disputes:

  • Initial Review: Assess the strength of your case.
  • Formal Action: If your case is strong, we can proceed with HMRC appeals or Tax Tribunal appeals and negotiations.
  • Alternative Strategies: Where it may be harder to successfully challenge matters, we advise on other mitigation options.