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Gary Gardner


Tax Risk & Dispute Resolution

Find me on LinkedIn

+44 (0)20 7544 8784

Drawing on my experience as a former HM Inspector of Taxes, I provide strategic, pragmatic and innovative solutions for my business and private clients to resolve their tax disputes.

I’m a tax adviser specialising in the management of tax disputes with HM Revenue & Customs (HMRC).

I joined Blick Rothenberg in April 2015 and, with over 25 years in the profession, I’m experienced in resolving a wide range of tax enquiries and disputes with HMRC for high net worth individuals and businesses.

Drawing on my experience as a former HM Inspector of Taxes, I provide strategic, pragmatic and innovative solutions for my business and private clients to resolve tax disputes conducted by HMRC’s Fraud Investigation Service, Large Business Directorate, Local Compliance (Large & Complex and Small and Medium Businesses) and the High Net Worth Unit.

Wherever possible I try to identify opportunities to reach a favourable outcome and settlement with HMRC using the Alternative Dispute Resolution (ADR) process, where appropriate.

Where ADR isn’t feasible, I work with leading tax Counsel to support and lead corporate and private clients through every stage of the litigation process, from lodging appeals through to substantive hearings before the Tax Tribunals.

I write for the professional press and have had articles published in industry publications such as Taxation, and Bloomberg Tax, as well as in the national broadsheets. I can also be found presenting seminars both internally and externally on tax dispute matters.

I enjoy the challenging nature of the work I do and the wide range of clients I act for, as well as working with my excellent colleagues here at Blick Rothenberg.

Specialist areas

  • Advising on HMRC investigations into high net worth individuals, large businesses, and SMEs
  • Experienced at assisting clients with making managed disclosures to HMRC in order to bring their UK affairs up to date, including using HMRC’s Worldwide Disclosure Facility (WDF)
  • Experience of assisting corporate clients with making disclosures through HMRC’s Profit Diversion Compliance Facility (PDCF)Experience in dealing with cross-border tax enquiries, corporate residency/central management and control
  • Expert in advising on the tax issues relating to permanent establishments (PEs), Transfer Pricing, diverted profits tax (DPT) and the Profit Diversion Compliance Facility.
  • Expert adviser on investigations undertaken by HMRC’s Fraud Investigation Service, including the Contractual Disclosure Facility/COP9 and COP8.
  • Experienced in litigation support and appeals to the First-tier Tax Tribunal, the Upper Tribunal and Higher Courts.
  • Expert in the Corporate Criminal Offence of Failing to Prevent the Facilitation of Tax Fraud, including advising corporate clients on compliance and delivering training solutions.
  • HMRC assessing powers, appeals, internal reviews and litigation
  • HMRC’s statutory discretion

I am based at

Covent Garden

Contact Gary


HMRC Investigations 17 December 2021

Top tips for taxpayers facing investigation

It is quite possible that taxpayers could still receive enquiry notices before the festive season gets into swing.

02 November 2021

Domicile enquiries: HMRC’s approach and what taxpayers need to be aware of

Tax Risk & Dispute Resolution Partner Fiona Fernie takes a look at HMRC’s approach to domicile enquiries and what steps taxpayers should take.

09 September 2021

Revisiting the Corporate Criminal Offences legislation

We review the Corporate Criminal Offences legislation and the compliance risks that many businesses are unknowingly exposing themselves to.