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HMRC disputes and director exposure

HMRC Pursuing You Personally for a Company Tax Debt?

A company tax debt is not automatically a director's personal debt. The legal route used by HMRC, the periods involved and the evidence relied upon must be identified before preparing a response.

Identify the actual HMRC notice

HMRC has different statutory powers for different taxes and circumstances. A Personal Liability Notice, penalty assessment, joint and several liability notice or ordinary company debt correspondence are not interchangeable. The notice, statutory basis, issue date and review or appeal instructions are critical.

Reconstruct the tax and payment history

Organise returns, PAYE and National Insurance records where relevant, VAT returns, payment allocations, correspondence, bank records and company management information. Match the periods and sums HMRC identifies rather than relying on an aggregate balance.

Examine the director's factual involvement

Build a chronology of appointments, financial control, payroll or tax responsibilities, professional instructions and HMRC contact. Evidence about who made decisions may matter, but absence of day-to-day bookkeeping responsibility is not automatically a defence.

What to send first

Provide the complete HMRC notice and enclosures, the envelope or date received where available, company tax references with unnecessary personal identifiers redacted, returns, payment records, accountant correspondence and all stated deadlines.

What we prepare

A notice and deadline register, transaction and tax-period schedule, evidence index, discrepancy matrix and draft factual correspondence within our permitted scope. Tax appeals and specialist legal or tax advice may be necessary.

Related director case preparation

Independent case preparation — important boundaries

Wolfe & Black is an independent case-preparation consultancy, not a firm of solicitors, an insolvency practitioner or a regulated tax adviser. We do not undertake reserved legal activities, conduct litigation, exercise rights of audience or guarantee outcomes. Seek appropriately qualified legal, insolvency or tax advice where required.

Director and insolvency support

Related problems we can help you prepare for

One investigation or demand can overlap with other issues. Identify each notice and deadline separately. We can help organise the records and allegations for an initial assessment.

Independent non-reserved case preparation, not a solicitor's practice. If proceedings or formal response deadlines apply, seek appropriately authorised legal advice promptly. An enquiry does not suspend a deadline.

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