For Professionals
When Your Client's Innovation Tax Case Gets Complicated
You're a good accountant. You handle R&D claims, SEIS applications and Patent Box elections for your clients competently. But occasionally a case lands on your desk that doesn't fit the template.
HMRC opens a compliance check on an R&D claim and the questions go beyond standard. An SEIS advance assurance comes back rejected and you're not sure why. A client's Patent Box computation is under scrutiny. An investor is threatening action because their EIS relief is at risk.
That's when you need a specialist. That's what I do.
Who I Am
I'm Steve Livingston. Fellow of the ICAEW, LLB, 25 years in innovation tax. I trained at KPMG, made partner at Crowe, and have run my own specialist practice since 2013.
I don't prepare routine claims. I handle the cases that keep other advisors up at night.
What I Handle
HMRC Enquiry Defence
When your client's R&D claim is under HMRC challenge - whether it's a compliance check, a full enquiry, or an allegation of fraud - I take it from your desk to resolution. I've defended claims worth hundreds of thousands of pounds,
including cases where HMRC alleged fraud. Both were accepted without amendment. I've taken cases to the point of tribunal and had them resolved in the client's favour.
Complex SEIS/EIS Structuring
Connected persons complications. Financial health requirement failures. Asset purchases from predecessor entities. Multi-round funding with SEIS to EIS transitions. Rejected advance assurance applications. The structures that don't fit
HMRC's standard template - I unpick them and get them approved.
Patent Box
Multi-stream income allocation, IP ownership across group structures, transfer pricing on intra-group arrangements, and HMRC challenges to existing computations. The technical work that sits beyond a standard Patent Box election.
EMI Disputes
Valuation challenges from HMRC, disqualifying events, restructuring complications and interaction between EMI and SEIS/EIS limits.
How It Works For You
Your client stays your client. I work alongside you, not instead of you. I handle the specialist technical issue, you maintain the relationship. Your client sees you as the firm that brought in the right expert at the right time.
I don't compete with you. I don't offer compliance, bookkeeping, accounts preparation, VAT, payroll, or general tax advisory. I have no interest in your client's annual return. I want the one case a year that needs 25 years of
specialist experience.
Referral, not replacement. You refer the complex case to me. I deliver the specialist work. I report back to you. When it's resolved, I step away. If your client needs ongoing compliance support, I refer that work to professionals like
you.
What I Can Do For Your Firm
CPD Sessions
I offer complimentary CPD sessions for accounting firm tax teams on innovation tax - practical, case-based, focused on the traps your clients are most likely to encounter and how to spot them early. Topics include:
- HMRC's current approach to R&D compliance checks - what triggers them and what to expect
- SEIS/EIS structuring - the connected persons and financial health traps that catch most advisors
- Patent Box - when the standard computation isn't enough
- When to bring in a specialist (and how to position it with your client)
These sessions are genuinely useful for your team's development and give you a direct line to specialist support when you need it.
Second Opinion Reviews
If your team prepares R&D claims or SEIS/EIS applications and you want a specialist eye before submission, I offer technical reviews. This is particularly valuable for higher-value claims or structures with any element of complexity.
It costs significantly less than defending a challenge after the fact.
Retainer Arrangements
For firms with a portfolio of clients regularly encountering innovation tax issues, I offer an annual retainer for access to Senior Tax Counsel. You get priority response on technical queries, a named specialist for complex cases, and
the confidence that comes from having a dedicated expert on call.
The Numbers
- 94% of HMRC enquiries I've handled resolved without claim reductions
- Average enquiry duration under my management: 8 months (vs 18-24 months HMRC average)
- Over £4m in R&D claims successfully defended in the past 24 months
Get In Touch
If you're an accountant, lawyer, corporate finance advisor, or investor and you want to discuss how specialist innovation tax support could work for your practice, I'd welcome a conversation.
No sales pitch. No obligation. Just a straightforward discussion about whether there's a fit.
Book a call with Steve Livingston
Email: stevelivingston@iptaxsolutions.co.uk
Or if a CPD session for your team would be useful, let me know your availability and I'll put something together.
Steve Livingston FCA LLB - IP Tax Solutions Ltd
M-SPARC, Menai Science Park, Gaerwen, Anglesey
ICAEW Regulated