LEXLAW Solicitors & Barristers
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.
An Account Freezing Order is one of the most disruptive financial enforcement tools available to UK authorities, allowing HMRC, the police and the National Crime Agency to freeze money held in a UK bank or building society account at a very early stage of an investigation. In many cases, the account holder has not been charged with any criminal offence, and may not even be aware that they are under investigation until the account is suddenly inaccessible.
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.
The High Court held RBS and Natwest vicariously liable for traders assisting in fraud, despite lacking actual knowledge of the fraud. Read the full judgment for Bilta (UK) Ltd & Ors v Natwest Markets Plc & Anor [2020] EWHC 546 (Ch), which case concerned legal privilege amongst allegations of fraudulent trading and dishonest assistance.
HMRC uses complex expert evidence from KPMG in VAT and MTIC fraud cases to challenge appellants. Without your own expert response, this evidence may go uncontested, risking your case. Early and expert legal support is vital to protect your interests and effectively counter HMRC’s claims. Contact Lexlaw Solicitors for professional advice and representation.
The Court of Appeal has clarified the ‘Kittel’ test in VAT fraud cases, ruling that the key question is whether a trader should have known their transactions were connected to fraud, rather than whether it was merely likely. HMRC bears the burden of proof to show the trader’s knowledge. This decision helps genuine traders defend against denied input tax claims, but full, robust responses to HMRC’s fraud indicators remain essential. Contact Lexlaw for expert VAT litigation advice and representation.
The Brayfal Tax Appeal Decision highlights the significance of a three-person VAT tribunal in complex high-value fraud cases. Unlike a two-member tribunal with a judge, where the judge’s opinion can be overruled by the other member, a three-person panel ensures balanced decision-making. Lexlaw advocates for future VAT tribunal hearings to be heard by two chairmen and one judge to improve fairness and expertise. Contact Lexlaw to discuss the implications of this decision and get expert VAT litigation support.