
Beyond Kittel: When HMRC Alleges the Taxpayer Was the Fraudster
HMRC is increasingly alleging not just that a taxpayer knew about fraud, but that it actively participated in or orchestrated it. We explain why that distinction changes everything.
CTM is a specialist tax disputes practice advising individuals and businesses facing serious HMRC investigations, VAT disputes, Kittel challenges, discovery assessments, insolvency issues and tax tribunal appeals. We act nationally on complex, high-risk matters requiring senior-level strategy, negotiation and experienced Tribunal advocacy.
We advise in serious and high-risk cases where HMRC scrutiny may lead to assessments, penalties, disclosures or Tribunal proceedings.
Learn MoreWe advise on VAT assessments, input tax denials, penalty determinations and procedural issues arising in VAT enquiries.
Learn MoreWe challenge discovery assessments on grounds including time limits, validity and whether HMRC acted reasonably.
Learn MoreWe advise on HMRC penalty assessments including inaccuracy penalties, failure to notify and personal liability notices.
Learn MoreWe are skilled in dealing with the threat of winding up action, with many options available to frustrate HMRC.
Learn MoreWe negotiate settlement of tax disputes and secure Time to Pay arrangements where liabilities cannot be met in full.
Learn MoreCTM's ethos is simply to provide real value for money and to leave each client feeling fully satisfied with our service. We achieve this through our 4 core values:
We pride ourselves in our ability to achieve excellent results, but to also work quickly
Our success speaks for itself and we are able to maintain our high standards
The professionalism of our staff is monitored by the Partners and Directors
We are always up to date with HMRC procedure, new legislation and relevant caselaw
“I would just like to say that the way I was handled by the CTM staff from top to bottom was professional, discrete and with the utmost respect. Ending up with a settlement figure that was both acceptable to HMRC and myself was no mean feat and the negotiating skills are second to none. Well done and I will recommend you.
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“HMRC refused to repay my business several hundred thousand pounds of VAT that was rightfully mine and I instructed CTM to appeal the decision to the Tax Tribunal. After several days in Tribunal, I was informed that the appeal was successful
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“CTM were instrumental in helping to prevent my medical and cosmetic treatments business from going under due to VAT issues, just when I thought I would have to lay off my staff and break the news to my loyal clients.
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HMRC is increasingly alleging not just that a taxpayer knew about fraud, but that it actively participated in or orchestrated it. We explain why that distinction changes everything.

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