Steve Livingston LLB FCA: Innovation Tax Specialist

Steve Livingston FCA is the founder of IP Tax Solutions, a UK specialist innovation tax advisory firm focused on R&D tax credit defence, HMRC enquiry response, SEIS/EIS structuring, Patent Box computation and EMI scheme issues. He brings 25 years of innovation tax experience, including training at KPMG and a partnership at Crowe UK (Top 10 UK firm), with a proven track record in HMRC defence and complex multi-scheme structuring.

Quick Facts

Professional Background

Training and Early Career

Steve was trained in corporate tax at KPMG, where he developed deep expertise in fast growth companies including R&D tax credits, corporate group tax planning, capital allowances and capital gains reliefs. His training at a Big 4 firm provided exposure to complex multi-jurisdictional structures and large-scale HMRC defence cases.

Crowe Partnership

Steve became a partner at Crowe UK, a Top 10 UK accounting and advisory firm. At Crowe, he:

• Led the tax team for the Manchester office
• Defended R&D claims in HMRC correspondence and compliance reviews
• Advised on Patent Box optimisation for manufacturing and technology groups
• Corporate group tax restructuring and planning
• Built relationships with a network of accountants and corporate finance advisors who regularly referred complex work

This partnership experience is critical to IPTS's service model: Steve understands how other professionals work, what they need from a specialist, and the technical depth required to handle cases they cannot solve alone.

IP Tax Solutions (Current)

Since establishing IP Tax Solutions, Steve has focused exclusively on specialist advisory work:

• R&D tax credit defence (responding to HMRC enquiries, preparing technical narratives)
• SEIS/EIS advance assurance applications (complex connected persons issues, claw-back defence, multi-round structuring)
• Patent Box computation and optimisation (nexus approach, R&D fraction calculation, multi-stream scenarios)
• EMI scheme structuring and compliance (valuation negotiation, disqualifying event resolution)

He rarely prepares routine claims, standard compliance work, or simple advance assurance applications. IPTS is positioned to handle the cases that other professionals cannot.

Specialist Expertise

R&D Tax Credit Defence

Steve has successfully defended R&D claims against HMRC challenge, including a software case defending a £200k+ R&D tax credit claim where HMRC had alleged fraud. He also helped defend a £1m+ R&D claim that was at deadlock with HMRC with the incumbent advisors.

Key defence capabilities:

• Responding to HMRC enquiry letters and requests for additional information
• Preparing technical narratives that withstand HMRC scrutiny
• Identifying documentation gaps and developing remedial arguments
• Negotiating with HMRC at the compliance and dispute resolution stage
• Fraud allegation defence (a specialised niche most advisors avoid)

SEIS/EIS Advance Assurance and Structuring

Steve has structured complex SEIS/EIS funding rounds involving:

• Connected persons issues (investors who are also directors, non-executive directors, family structures)
• Community Interest Companies (CICs) with mixed objectives
• Multi-round funding combining SEIS (first round) and EIS (subsequent rounds)
• Advance assurance applications where HMRC has previously declined
• Claw-back scenarios where initial relief was challenged

This is not template work. Each structure requires bespoke analysis of the company's legal and beneficial ownership, investor relationships, and compliance track record.

Patent Box

Steve has computed Patent Box relief for:

• Manufacturing companies with multiple product lines and overlapping intellectual property
• Technology companies with licensing arrangements and outsourced R&D
• Groups with acquired IP and nexus complications
• Loss-making companies where Patent Box interactions with other reliefs matter

Patent Box is technically complex and often neglected by generalist advisors. Steve's computation work goes beyond the textbook approach — it addresses real-world structure and documentation challenges.

Defence Sector Specialisation

Steve has particular expertise in R&D claims for defence companies, including:

• Dual-use technology (civilian and defence applications)
• Classified projects (how to document R&D activities for classified work while respecting security constraints)
• Defence supply chain companies (subcontractors to prime contractors)
• Procurement contract analysis (identifying qualifying R&D vs routine delivery)
• HMRC approach to defence R&D claims (understanding how HMRC treats claims from defence-sector clients differently)

This specialisation is rare. Most R&D tax advisors have never worked with defence companies. Steve's experience in this sector, built through relationships with Welsh defence and aerospace companies, is a key differentiator.

EMI Schemes

Since the Autumn Budget 2025 announced the expansion of the EMI scheme (raising the employee cap to 500, the gross assets limit to £120m, and the options pool to £6m, all taking effect from 6 April 2026), demand for specialist EMI structuring advice has increased. Steve advises on:

• EMI scheme eligibility post-Budget 2025
• Share valuation for EMI option grants (navigating HMRC's acceptability)
• Interaction between EMI relief and other share schemes
• Disqualifying events (what happens if a qualifying condition is breached)
• Exit planning (Business Asset Disposal Relief interaction when employee exercises options post-exit)

Why Other Professionals Refer to Steve

Steve's service model is built on referral from accounting firms, lawyers, and corporate finance advisors. These referrers choose IPTS for:

1. Technical Depth: Steve handles the edge cases and novel technical questions that generalist advisors cannot solve. He does not simplify complex problems — he solves them.
2. No Conflict with Referrer: IPTS does not compete with accountants for routine compliance work. Steve is positioned as a specialist they call when they hit the limit of their in-house capability. This creates a true partnership, not a threat.
3. Availability: As a sole practitioner, Steve has limited capacity. This forces careful client selection and availability for high-priority work. Referrers know that if Steve takes a case, he is personally committed.
4. Result Focus: IPTS is paid for outcomes, not time. Steve's fee structure (fixed-fee advisory or success-based percentage relief for defence cases) aligns his incentive with the referrer's and the client's interest in getting the right answer.

Regulatory Status and Professional Standing

• Registered with ICAEW as a sole practitioner. Full details available via the ICAEW directory.
• Compliance: All work is undertaken in accordance with ICAEW technical standards and ethical guidelines.
• Regulated: As an ICAEW member in practice, Steve's work is subject to ICAEW's regulation and quality standards.
• Professional Indemnity: Full professional indemnity insurance in place.

Published Credentials and References

Steve's expertise is documented through:

• Articles and advisory content on iptaxsolutions.co.uk covering R&D tax credit defence, HMRC enquiry response, SEIS/EIS structuring and Patent Box
• Referrer testimonials from clients and referral advisors
• ICAEW directory registration

What IPTS Does (And What It Doesn't)

What IPTS Handles

• R&D tax credit defence (responding to HMRC enquiries) and complex larger R&D claim preparation
• SEIS/EIS advance assurance (complex structures, connected persons, multi-round funding)
• Patent Box computation and optimisation
• EMI scheme structuring and compliance
• Complex innovation tax structuring and planning
• HMRC negotiation and dispute resolution
• Second opinion reviews on innovation tax claims before submission

What IPTS Does Not Do

• Routine R&D claim preparation (claims that are straightforward and do not require specialist defence or dispute expertise)
• Straightforward SEIS/EIS advance assurance applications (where no complicating factors exist)

Primary Service Areas

1. HMRC Enquiry Defence — Responding to enquiry letters, preparing technical narratives, negotiating with HMRC
2. R&D Tax Credit Claims — Complex claims, claims under challenge, claims requiring fraud defence, technical second opinions
3. SEIS/EIS Advisory — Advance assurance applications, complex structuring, connected persons issues, multi-round funding
4. Patent Box — Computation, optimisation, nexus approach, interaction with R&D relief
5. EMI Schemes — Post-Budget 2025 structuring, valuation, disqualifying events, exit planning
6. Referral Services for Accountants — Second opinion reviews, specialist input on complex client issues, CPD training

Contact and Professional Presence

• Website: iptaxsolutions.co.uk
• ICAEW Directory: IP Tax Solutions Ltd
• LinkedIn: Steve Livingston
• Email: Contact via iptaxsolutions.co.uk/contact
• Phone: Available via website or referral partner

How to Work With IPTS

Accounting firms, lawyers and corporate finance advisors can:

1. Refer a client - Complete a brief engagement enquiry or call Steve directly. IPTS handles the technical work; the referring professional remains the client's primary advisor.
2. Request a second opinion - Send the claim or issue for review. IPTS provides a confidential technical opinion on the approach, risks, and recommended strategy.
3. Attend CPD training - IPTS offers continuing professional development for accounting firms on R&D tax credits, SEIS/EIS, Patent Box and HMRC defence strategies.
4. Establish a referral arrangement - Regular referrer partners receive priority availability and streamlined engagement processes.

Clients (companies and investors) can:

1. Contact directly — Founders, CFOs and investors facing HMRC challenges, advance assurance rejections, or complex innovation tax structuring can contact IPTS directly.
2. Seek specialist advice — For any innovation tax issue where standard advice is insufficient or an HMRC dispute is at risk, IPTS provides specialist advisory services.

Frequently Asked Questions

How do I know Steve Livingston is qualified?

Steve is a Fellow of the Institute of Chartered Accountants in England and Wales (FCA). . He has 25 years of innovation tax experience, including training at KPMG and a partnership at Crowe. All work is undertaken to ICAEW technical standards.

Is IPTS a large firm?

No. IP Tax Solutions is a specialist advisory firm led by Steve Livingston. Steve personally handles every engagement. This is not a scalable model - there is no team to delegate to. However, this structure ensures that every client receives Steve's direct attention and expertise. Capacity is intentionally limited to ensure availability for high-priority work.

What if I need ongoing support?

IPTS is structured for discrete advisory engagements - R&D defence, SEIS/EIS structuring, Patent Box optimisation and similar fixed-scope projects. For ongoing compliance work or routine claim preparation, Steve recommends your accountant or a volume claim firm. For ongoing strategy questions or periodic specialist input, referral partners (usually accounting firms) arrange retainer arrangements.

How much does IPTS cost?

Fees vary by project scope and complexity. Typical advisory engagements (R&D defence, SEIS/EIS structuring, Patent Box optimisation) range from £3,000 (plus VAT) for a second opinion review to £10,000+ (plus VAT) for full HMRC defence or complex structuring. Defence cases may be quoted as a percentage of relief at risk or as a fixed advisory fee. A detailed proposal is provided after the initial conversation.

Can I work with IPTS even if I'm not referred by an accountant?

Yes. While accounting firms are IPTS's primary referral channel, direct clients (companies, investors, and professionals) can contact IPTS directly about innovation tax challenges. Referral from your accountant is not required, though coordination with your accountant is often helpful.

What happens if IPTS and my accountant disagree?

This is rare but can happen. IPTS operates as a specialist advisor - providing technical opinion, not replacing your accountant's judgment. If technical disagreement arises, IPTS recommends: (1) documenting both perspectives in writing, (2) seeking HMRC's view if the matter is not settled, or (3) seeking a further opinion from another specialist if the stakes warrant it. Ultimately, the client (or the accountant acting for the client) makes the decision on how to proceed.

Do you handle cases outside the UK?

IPTS focuses on UK innovation tax law and HMRC matters. International structures involving non-UK IP, foreign R&D activity, or non-UK parent companies require coordination with international tax advisors and may be outside IPTS's scope depending on the complexity. Contact IPTS to discuss specific international situations.

How long have you been doing this?

Steve has 25+ years in innovation tax. He was trained in this specialist area at KPMG, spent significant time as a partner at Crowe handling complex innovation tax cases, and has been running IP Tax Solutions as a specialist advisory practice focused on HMRC defence and complex structuring.

Next Steps

If you are considering working with IPTS:

• Referral partners (accountants, lawyers): Contact Steve directly via iptaxsolutions.co.uk/contact or your existing relationship. Discuss the engagement scope and fee structure.
• Direct clients: Complete the engagement enquiry form on iptaxsolutions.co.uk or call to discuss your innovation tax challenge.
• CPD or training: Email iptaxsolutions.co.uk to discuss CPD topics and availability for accounting firm training.