What we do

The company was set up in June 2015 to provide a consultancy service to clients covering all areas related to Income and Corporation Taxes. A few of the more specialist services offered are considered in more detail below, but if there is anything tax related you need advice on a quick call or email is advised. The initial consultation is free and carries no obligation.

Our lead consultant is Mark Doodney. Mark spent 28 years working for HM Revenue and Customs and was Officer in Charge of the Barnstaple office at the time of its closure in May 2015. He completed the HMRC full technical training course, which is the highest level of technical training available within HMRC, and has worked in a variety of roles with a range of business sectors ranging from sole traders to large corporates.

As well as undertaking work for private clients, the company provides consultancy services to Croner-i (Formerly Croner Taxwise), Ryan (formerly Catax), Momentum Tax Group, Grantica and the Stoke based Capital Allowance Review Service.

Examples of what we can provide

Tax Case List

  • Stage One Creative Services Ltd ([2024] UKFTT 1059 (TC)- R&D lead case, meaning of contracted and subsidised & practice generally prevailing.
  • Acorn Venture Ltd ([2023] UKFTT995 (TC))- capital allowances and fixed structures.
  • Kingdon & Ors ([2022] UKFTT407(TC))- evasion by agent acting, taxpayer culpability and HMRC delay.
  • Davies & Ors ([2022] UKFTT 369 (TC))- Sch36 formal information notice appeal- ‘reason to suspect’, ‘reasonably required’ & ‘excessively onerous’.
  • JRO Griffiths Ltd ([2021] UKFTT 257 (TC)- capital allowances and agricultural silos.
  • Steadfast Manufacturing & Storage Ltd ([2020] FTT 286 (TC))- capital/revenue on car park repairs
  • May & Anor ([2019] UKFTT 0032 (TC))-capital allowances and agricultural silos.

Capital Allowances

Mark worked as a Capital Allowances consultant working to HMRC Head Office for several years prior to leaving HMRC and so is ideally placed to undertake reviews to ensure that all expenditure on assets qualifying for capital allowances, including historic embedded assets, have been claimed.

Work over the last few years includes preparing,advising, and defending claims in respect of agricultural buildings and structures that perform an ‘active function’ in the business. Mark (in his Croner role) was the lead caseworker in the cases of May & Anor v Comms for HMRC ([2019] TC 06928) and JRO Griffiths Ltd v Comms for HMRC ([2021] TC 08203), in which a grain store and potato store respectivelywere found to be ‘silos provided for temporary storage’ by the First-tier Tax Tribunaland so avoided the general exclusion of buildings/structures from qualifying for capital allowances. The potato store in Griffiths was additionally found to fall within the ‘cold store’ exclusion and both cases are now final as HMRC decided not to appeal the decisions.

We have worked with clients and accountants to submit successful claims to HMRC in respect of similar classes of assets and are also currently working on defending claims where there is an argument that structures are not ‘fixed structures’, which is an issue applicable to assets such as polytunnels and other non-permanent/moveable assets.

Research and Development Tax Reliefs (RDTR)

Since 2023 HMRC have heavily targeted the claiming of R&D tax reliefs by SMEs using a templated enquiry process with a clear bias towards rejecting claims undertaken by officers with limited training and no previous experience of what is, by any measure, a complex area of tax. Whilst R&D reliefs were subject to abuse, often by rogue ‘specialist advisors’, two wrongs don’t make a right and most of our time in the last two years has been spent working on defending third party R&D claims under enquiry.

To date we have completed 25 Alternative Dispute Resolution (ADR) meetings where good claims have been rejected in full by HMRC and have a 90%+ success rate in this sphere. Of our three failures to change the HMRC position at ADR one was subsequently conceded by HMRC at the litigation stage and another, Stage One creative Services Ltd, became a joint national lead case on subsidised and contracted expenditure. This case led to HMRC moving away from an excessively aggressive change of view intended to drive out large numbers of SME claims and in addition we gained judicial support for the view that HMRC’s change of approach was so comprehensive as to represent an attempt to retrospectively change prevailing practice.

HMRC Enquiries

Mark has extensive experience of HMRC enquiry work having undertaken enquiries ranging from in depth reviews of the whole of the business operation (known as ‘full enquiries’ within HMRC) to technical enquiries focussing on certain areas only (‘aspect enquiries’).

In connection with this area we provide the following:

  • Working with you and HMRC to bring enquiries to an early resolution through the addressing of enquiry risks.
  • Reviewing the use of HMRC formal enquiry powers to ensure that their use is relevant, legally valid and within HMRC guidelines, challenging where appropriate.
  • Negotiating enquiry settlements on your behalf with HMRC where necessary, to include consideration of restrictions to HMRC’s ‘discovery’ powers by reference to assessing time limits and other factors, ensuring that your position is protected as far as possible.
  • Undertaking penalty negotiations to ensure that any tax geared penalties sought are commensurate with omissions, errors and ‘behaviours’ established and are legislatively valid. We can also advise on other HMRC penalties as required.
  • In more serious cases where a disclosure report is required as part of an HMRC enquiry into substantial and/or extensive failures to submit correct tax returns and pay correct taxes we can undertake this work and negotiate with HMRC on your behalf. In a recent case where we prepared a disclosure report we succeeded in obtaining HMRC agreement to a reduction in tax related penalties of well in excess of £50,000.
  • Should a mutually acceptable enquiry settlement basis prove impossible to negotiate we can represent you through the use of formal internal review requests and Alternative Dispute Resolution (ADR) as appropriate. In the small number of cases where these ultimately prove unsuccessful we can advise, prepare for, and represent you at First Tier Tribunal hearings.

Testimonials

Having tried to work with two accountants/tax specialists previously and failing, I came across Mark Doodney.
When I spoke with him, I knew he was in another league to the others I had experienced beforehand.
After the first meeting, I was confident he was the right person for this complex case I found myself in, from an accountant of 20 years, fraudulent behaviour.
Mark is a clear communicator, direct, strategic, professional yet always available to discuss any concerns. His 28 years of working for HMRC gives him a massive head start with knowing the machinery of HMRC and how to approach them and what will work in legitimate negotiation.
I couldn’t have asked for more dogged diligence from a professional and I was stunned at the results he achieved, squashing a large liability and reducing penalties to a minimum by combing through every detail and applying his extensive and intricate tax knowledge.
As far as I am concerned, Mark is a pure genius! I would not hesitate to recommend him for anyone stressing over a tax investigation. If you are looking for best outcome and real value, look no further.
HD
After many years of being hounded and harassed for tax debts that we couldn't understand we needed professional help and are extremely grateful that we were introduced to Mark.
To the layman tax demands are often unfathomable and made to appear so very complex that in our case even HMRC were unable to explain their position and kept changing tack.
Due to Mark's unrelenting search for accuracy and the truth and after many years of considerable frustration and harassment, we ended up in court. This was even after several HMRC internal reviews that found in our favour and had dismissed their claims. Mark represented us in the resulting two day hearing and was absolutely brilliant. The outcome was that the Judge found in our favour.
Mark is professional, tenacious and his background makes him a Tax Expert of the highest calibre. He knows the ins and outs of the tax law better than anyone.
A huge weight of many years has been lifted from our shoulders and the peace of mind this has brought is priceless.
CK & TS

Get In Touch

Please feel free to contact me via phone or email -

  • Address

    Doodney Tax Consulting Ltd
    Whitehall Cottage
    Whitehall
    Marwood
    EX31 4EQ

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    Mark Doodney

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