The tax landscape has become more complex, more scrutinised and more unpredictable.
That isn’t a complaint. It’s simply the current operating reality.
In this environment, accountancy can either be reactive compliance — or it can be structural strategy.
At P10, compliance is handled properly and on time. But the real value sits in reviewing ownership, identifying risk early and ensuring tax and cash flow positioning supports long-term plans.
Two recent engagements demonstrate why that distinction matters.
Alongside navigating the current HMRC environment, some of the most valuable work we do sits away from compliance entirely.
A recent advisory engagement involved a client operating seven companies, all under personal ownership.
The businesses were trading successfully. Structurally, however, they were fragmented and lacked flexibility.
We undertook a full review of the ownership position and implemented a group restructure bringing all seven entities under a newly formed holding company.
The immediate savings are difficult to quantify in isolation.
But in terms of future proofing the business, facilitating international growth and protecting exit optionality, this was a significant structural improvement.
In a separate matter, we were engaged by a property development company nearing completion of a 21-unit apartment scheme.
The business was struggling to exit its development finance facility whilst retaining selected assets. The owners believed that keeping the properties would result in tax liabilities of over £1 million.
Our review identified a different route.
Before our involvement, the position appeared constrained and potentially exposed to a seven-figure tax liability.
Following review and implementation, the business retained its assets, secured the necessary finance and removed a significant perceived tax exposure.
Beyond the immediate outcome, the structure now supports long-term flexibility and future planning that had not previously been considered.
We don’t usually use our content to have a dig at HMRC.
But it would be disingenuous not to acknowledge what we’re seeing at the moment.
In short, HMRC’s current conduct is creating avoidable friction for businesses that are doing everything correctly.
Returns are being filed on time.
Registrations are being submitted properly.
Positions are being reconciled.
Yet the environment we’re operating in has become increasingly unpredictable.
Before we outline what we are seeing with HMRC - from VAT registration delays to repayment enquiries and offset issues - it is worth clarifying something.
Accountancy at P10 is not just filing returns and responding to correspondence.
Compliance is handled properly and on time. But our role also includes reviewing structure, identifying risk early and ensuring cash flow and tax positioning support longer-term plans.
That distinction matters, particularly in an environment that has become increasingly unpredictable.
We are seeing VAT registrations not being processed or rejected without explanation.
The difficulty is this: without a VAT registration number, we cannot formally act as agent. And without agent status, HMRC will often not speak to us.
It becomes a circular problem that is unnecessarily difficult to resolve and is causing significant delays for businesses trying to get properly registered and trading.
We are also seeing first VAT returns that show a repayment automatically trigger an enquiry.
For many new businesses, that first repayment is relied upon as part of early cash flow planning. The enquiry process ultimately delays the repayment being made, even where the return itself is accurate and fully supported.
It doesn’t mean anything is wrong.
But it does mean timeframes are extending.
More broadly, enquiry activity in general appears to have increased.
Routine matters that would previously have passed without issue are now more likely to be reviewed. That in itself isn’t necessarily a problem, but it does extend timeframes and adds administrative weight to matters that used to be straightforward.
Telephone wait times can be excessive. A simple request can take significantly longer than expected, and the success of a call can sometimes depend on the individual HMRC officer handling it.
That variability makes it difficult to provide precise timelines, even when everything has been submitted correctly from our side.
We are also encountering HMRC delays when it comes to refunds and additional security checks being performed without clear reasoning.
In some cases, HMRC systems are not communicating correctly with one another, leading to submissions being rejected or penalties being issued for matters that have in fact been dealt with.
Those penalties then need to be appealed, which can create the impression that something has been missed, when in reality it is a systems issue that sits outside of both the client’s control and ours.
One of the more frustrating examples at present relates to CIS and Corporation Tax offsets.
We are seeing instances where CIS has been suffered and HMRC effectively owes the company money, yet the offset is not being processed correctly against Corporation Tax or PAYE liabilities.
In some cases, clients are being referred to debt collectors for unpaid liabilities when the underlying position is that HMRC has failed to offset or repay sums already due.
These situations are resolvable. But they require time and escalation.
Sometimes matters are processed quickly.
At other times, weeks or even months pass without movement.
That inconsistency makes it difficult to provide clear guidance on timing and can understandably lead to frustration where delays are assumed to sit with advisers rather than within HMRC’s systems.
So this note isn’t a complaint. It’s context.
Our standards have not changed. Returns continue to be filed correctly and on time. Issues are being chased and escalated where appropriate. Appeals are being made where penalties are incorrectly issued. Offsets are being reconciled and repayment claims followed through.
What has changed is the operating environment.
If you are expecting a VAT registration, a repayment, an offset or are concerned about correspondence you have received, speak to us early.
The earlier we are aware of potential pressure points, particularly around cash flow, the better we can plan around them.