How to Instruct a Tax Expert Witness

United Kingdom Matters Only

This guide applies to instructing tax expert witnesses in UK tax disputes only: HMRC assessments and investigations, First-tier Tribunal and Upper Tribunal appeals, and civil proceedings where English, Welsh, Scottish, or Northern Irish tax law and tribunal rules govern expert evidence. We do not cover non-UK tax jurisdictions.

For Tax Litigation Counsel

  1. Identify the technical tax issue, VAT, transfer pricing, IHT, CGT, ERS, SDLT, corporate avoidance, or professional negligence
  2. Determine expert type, Does the case need a tax technical expert, a forensic accountant, or both? See tax expert vs forensic accountant
  3. Check FTT category, Standard and complex track cases typically require expert evidence
  4. Prepare instructions, Specific technical questions to address; CPR Part 35 format required; include summary of material facts
  5. Provide documents, HMRC assessment, relevant correspondence, tax returns, financial records, and any HMRC reconstruction report
  6. Expert assessment, Expert reviews HMRC's position and advises on strength of challenge
  7. Report and hearing, CPR Part 35 report, response to written questions, supplemental report if needed, hearing attendance

For Forensic Accountants

Instruct a separate tax expert when the case raises technical tax analysis questions beyond forensic accounting expertise. Common scenarios include:

  • HMRC reconstruction produces a financial figure, but is the correct tax treatment applied to that figure?
  • POCA benefit calculation includes tax elements requiring technical analysis
  • Professional negligence claim requires assessment of whether tax advice was correct
  • Transfer pricing dispute requires arm's length analysis beyond financial accounting
  • VAT MTIC case requires knowledge test analysis, not just transaction tracing

Timeline: 7 Steps

StepActionTypical Timing
1Case assessment, identify expert needAt instruction / appeal filing
2Expert selection and initial enquiryWeek 1–2
3Letter of instruction and document bundleWeek 2–4
4Expert report (standard track)8–12 weeks
5Written questions and supplemental reportPre-hearing
6Hearing preparation and joint expert discussion4–8 weeks before hearing
7Tribunal hearing attendanceTypically 2–3 years from appeal

Red Flags When Selecting an Expert

  • No active tax practice, tax law changes constantly
  • No FTT testimony history in the relevant tax area
  • Cannot explain the disputed tax issue clearly to a non-specialist
  • Unfamiliar with current HMRC practice and recent tribunal decisions
  • Prior adverse judicial comments on their expert evidence

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