LEXLAW Solicitors & Barristers
LEXLAW forced HMRC to withdraw a near £1m VAT best judgment assessment after we demonstrated it had been issued against the wrong taxable person. A historic VAT registration error by HMRC lay at the root of the dispute. Our legal investigation with specialist tax counsel secured HMRC’s total defeat before trial.
We are the leading firm representing Directors and Companies facing HMRC Security Notices and we regularly succeed on behalf of clients. Here, our counsel successfully fought HMRC Security Notices that sought to impose over £215,000 in personal liability for VAT and PAYE debts. The case is a landmark victory against HMRC Notices of Requirement to give Security.
Personal Liability Notices (PLNs) are a powerful HMRC enforcement mechanism that can make company directors and officers personally liable for unpaid corporate tax debts, including PAYE, National Insurance Contributions, VAT, and CIS. In 2026, PLNs are increasingly used in insolvency and enforcement scenarios, placing directors’ personal assets and professional futures at direct risk.
A HMRC Time to Pay (TTP) arrangement lets businesses spread unpaid tax over manageable monthly instalments. In 2026, with HMRC enforcement increasing, well-prepared TTP proposals backed by financial evidence help avoid winding-up petitions, protect directors, and keep businesses trading.
Under the old Martland rules missing a tax tribunal appeal deadline meant case closure as time limits were treated as virtually absolute. The Upper Tribunal’s 2025 decision in Medpro v HMRC restores judicial discretion and elevates case merits. Taxpayers with credible explanations now have a realistic path to rescuing late appeals. Understanding the shift and presenting your circumstances effectively to a tribunal, could mean the difference between recovering a valid claim and losing it permanently.
The Tribunal in Hastings Insurance Services Ltd v HMRC confirmed that UK intermediaries can recover VAT on services provided to overseas insurers. This decision challenges HMRC’s interpretation of VAT law and sets a strong precedent for cross-border transactions.
Expert guide to VAT “reasonable excuse” defences. Learn how to successfully challenge HMRC penalties, surcharges & late filing penalties with proven legal strategies from specialist tax dispute solicitors.
A time-to-pay proposal enables a debtor to negotiate structured repayment terms with creditors, creating a legal pathway to avoid insolvency while ensuring creditors’ rights are protected. Commonly sought by companies with tax arrears, such arrangements require careful preparation and timely negotiation to maximise acceptance.
We successfully annulled a bankruptcy order against our client after HMRC failed to properly serve notice of a key hearing. Mr. Gaster proved this procedural error denied him the chance to present evidence of his ability to pay. The court’s judgment emphasized due process under Rule 10.23 of the Insolvency Rules 2016, exposing flaws in HMRC’s conduct and evidence on the adjournment notice.
In Purkiss v Kennedy, the High Court rejected a liquidator’s attempt to recover unpaid PAYE and NICs from Ethos Solutions Ltd’s failed tax avoidance scheme. The court found no fraudulent intent to evade HMRC under Insolvency Act 1986, Section 423. This case highlights HMRC’s challenges in tax recovery via insolvency law and the need to prove intent.