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Why Tax and Accounting Professionals Should Welcome Specialist Support in Tax Disputes

Following our December/January 2023 guest article “It Pays to Ask an Expert,” which examined the practical aspects of engaging a tax disputes specialist, this piece takes a step back to address a fundamental question: Why should accounting and tax professionals welcome this type of specialised assistance, and what advantages does it offer both practitioners and their clients?

This article examines:

  • The barriers preventing tax advisers and accountants from reaching out to specialists
  • How specialist expertise works alongside general practice capabilities
  • Key traits of advisers who make effective use of specialist resources

Barriers that prevent tax advisers and accountants from seeking specialist help

    The practitioners I collaborate with typically already understand the value that specialist input delivers, not just for their clients, but for their own practice. Understandably, I have limited direct contact with those who resist or postpone engaging specialists. That said, I regularly encounter the concerns that create hesitation, and these tend to follow predictable patterns.

    Taking HMRC enquiries as a personal criticism.

    Some advisers interpret HMRC’s actions as a direct challenge to their professional capabilities. This reaction appears frequently in tax dispute situations. When either the taxpayer or their adviser – or both – become emotionally attached to the point under scrutiny, it can undermine constructive strategy discussions and block potential resolution pathways.

    I recall being brought in by the widow of a taxpayer who had died from a heart attack, reportedly triggered by stress from an HMRC enquiry he had concealed from everyone. Though highly competent, the widow’s correspondence with HMRC was dominated by her grief and the emotional burden she was carrying. My role was to step in, prepare the required calculations, present a settlement proposal, and bring closure to the matter so she could begin to heal.

    Confusion when HMRC challenges clients they know are compliant.

    Advisers frequently express frustration: “HMRC ought to recognise that we operate correctly.” When this assumption proves unfounded, it creates a sense of unfairness.

    When HMRC’s concern about potential underpayment is incorrect, a straightforward discussion with the taxpayer, a quick verification, and a professional response demonstrating everything is in order should resolve matters. However, emotion can obstruct this process if an adviser feels insulted by HMRC’s implication that a mistake might have occurred.

    Anxiety about client criticism.

    Comments like “Surely you reviewed that?” or “What exactly am I paying you for?” can create significant emotional pressure. This intensifies when an investigation reveals something the adviser wasn’t aware of and must now discuss with the client.

    When I brought a tax adviser onto my disputes team, he asked for a meeting early in his tenure to discuss items he’d uncovered that a client needed to retrospectively report to HMRC. He was anxious because in his previous position, identifying issues that should have been declared earlier would have suggested that he, the adviser, had initially overlooked them, or could have been perceived that way. I put him at ease, explaining that this was precisely his role now: to identify these matters, work through them with the client, and regularise the tax position in the most beneficial and appropriate manner for the client.

    As specialists in tax disputes, we routinely handle conversations that could be awkward, delicate, and potentially intrusive. We can therefore provide valuable support to advisers who find such discussions daunting and aren’t certain how to approach them.

    Fear of client loss.

    For many practitioners, the most significant concern is that a specialist might uncover an issue, leading the client to think: “My accountant ought to have caught this.” Even when no specialist would make such a statement, the fear alone prevents advisers from seeking assistance.

    These factors explain why many accountants postpone or completely avoid seeking specialist guidance. They try to handle complicated disputes independently, even when they acknowledge that tax dispute work falls outside their area of expertise, because the perceived risk of losing a client seems greater than the risk of mismanaging the dispute.

    A tax adviser contacted me recently. She had attended my presentation on HMRC disclosures and subsequently engaged with a taxpayer requiring a disclosure. The adviser submitted a disclosure proposing £5k of tax across four years, despite the income stream being disclosed having existed for over 20 years. I have tremendous respect for this adviser, who reached out when HMRC rejected her disclosure and indicated their view that the tax owed was £50k.

    My approach proceeded as follows. First, I met with the adviser, who then introduced me to her client, I met them individually. During those meetings, I needed to demonstrate that I fully grasped each person’s perspective and knew the pathway to resolution. I then clarified to the taxpayer what the probable tax liability would be, helping them understand that £5k was never realistic and that the adviser had made the right decision in bringing me in at that stage. Once they accepted that £5k was never the correct figure, they were receptive to me working on the calculations to bring them down from £50k to something considerably lower, ultimately less than half, and the disclosure was settled within six months of that initial conversation.

    In another recent situation, an adviser sought my opinion on a disclosure she had drafted and was about to submit to HMRC covering eight years. I advised her that it likely didn’t need to extend to eight years, despite the income source having existed that long, and that she might not even need to include a penalty. Factoring in HMRC’s assessment time limits comes naturally to tax disputes specialists but, as they say, you can’t know what you haven’t learned.

    Our expertise – and how it supports yours

      Tax disputes can sometimes seem enigmatic. In past positions, even colleagues within the same organisation have asked me, “What is it that you actually do?” Some of this confusion arises because most tax specialists concentrate on a specific tax – corporation tax, VAT, private client matters, etc. Our specialisation isn’t a particular tax. Our specialisation is managing HMRC interactions across all tax types.

      We function as tax technicians, strategists, and, critically, advisers. Nearly every client comes to us feeling distressed or anxious. Addressing those emotions forms a core part of our expertise. You cannot succeed in this area unless you are genuinely a “people person,” able to manage not only the client’s worries but also those of their advisers.

      All our knowledge derives from actual cases, not academic texts. Over the years, we develop extensive experience handling diverse personalities, behaviours, and concerns from both taxpayers and their advisers.

      Specialist disputes work is inherently one-off in nature, making our professional networks invaluable to us. Since every engagement is unique, we place tremendous emphasis on reinforcing the relationship between the adviser and their client.

      Indeed, one of our central objectives is to ensure that when the dispute concludes:

      • the adviser’s credibility has been strengthened,
      • the client relationship has deepened, and
      • the client fully recognises the value of having both a trusted adviser and a specialist supporting them.

      Additionally, I always ask an adviser about their preferred level of involvement once I’ve been engaged, and I adjust my approach accordingly. For instance, they may wish to attend every meeting, or periodic email updates on progress may be sufficient. Regarding any computational work, they may prefer me to utilise their team members, and I’m pleased to do so. This allows the adviser to continue billing time to the assignment while their team member gains exposure to tax disputes work.

      Qualities of advisers who successfully utilise specialist support

        Advisers who leverage specialist support effectively typically exhibit several common qualities:

        They understand that disputes require a different approach.

        They recognise that managing HMRC’s conduct, expectations, and procedures is a distinct discipline requiring specialist knowledge, and that each case is unique.

        They prioritise results over control.

        Their focus is securing the optimal outcome for the client, rather than demonstrating they can manage every element independently.

        They safeguard their time and client relationships.

        Instead of allowing a lengthy dispute to consume time, emotional energy, and profitability, they engage help early, maintaining a positive and forward-looking relationship with the client. This is equally true of the most effective tax disputes specialists in my experience. They aim to resolve cases efficiently, never worried about where their next engagement will come from because when we demonstrate the right professional conduct, referrals naturally follow.

        They pose practical questions.

        For instance, about preparation for HMRC meetings, HMRC’s authority to request information from their clients, and whether advisers are obligated to provide what’s requested. They possess a solid grasp of the wider context while simultaneously recognising the risks of engaging directly with HMRC without support.

        Advisers who feel comfortable raising these questions, and who recognise when to bring in a specialist, typically achieve faster, smoother, and more favourable outcomes for their clients.

        Conclusion

        Tax disputes can be intricate and emotionally demanding, and outcomes can vary significantly based on who is representing the taxpayer and their experience level with HMRC. No adviser should feel obligated to manage this independently. Bringing in a specialist isn’t an admission of inadequacy, it’s a strategic choice that safeguards your client, elevates your credibility, and fortifies the adviser, client relationship.

        Whether the matter is minor or substantial, raising a question early always beats waiting until the dispute intensifies. When uncertain, ask. When concerned, collaborate. And when HMRC comes calling, don’t stand alone – get in touch.

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