JMTI
JMTI provides specialist representation in HMRC tax disputes for individuals and businesses. Straightforward advice when it matters most.
JMTI provides expert representation across a broad range of tax disputes, from the first HMRC letter to the final resolution.
Handling correspondence and negotiation with HMRC on your behalf, from initial enquiry letter through to closure notice.
Guiding clients through voluntary disclosures to limit penalties and secure the best possible outcome.
Received a decision or a View of the Matter from HMRC? JMTI can assess the opinion and provide guidance on the likelihood of challenging the decision.
Preparing and presenting appeals to the First-tier Tax Tribunal when a dispute between HMRC and the taxpayer cannot be resolved through ordinary channels.
COP9 investigations are amongst HMRC's most serious enquiries. JMTI can assist with all COP9 matters.
JMTI was founded by John Moxon, a Fellow of the Institute of Chartered Accountants in England and Wales (ICAEW). John qualified as a Chartered Accountant in 2009 and has held senior positions in the tax advisory sector since this time.
In 2019, he co-founded a boutique tax practice which was sold to an Employee Ownership Trust (EOT) in 2022. John has extensive experience in handling a range of HMRC enquiries, including appeals to the First-tier Tax Tribunal, COP8/9 cases and Alternative Dispute Resolution (ADR).
John is a regular contributor to Taxation Magazine, where he has written on the standard of HMRC enquiries and the difficulties they can present for taxpayers and advisers alike.
Outside of work, John is a lifelong Sheffield United season ticket holder and a keen mountaineer. His expeditions have taken him to the Himalayas, the Andes and beyond, with ascents including Cho Oyu, the world's sixth-highest mountain, as well as Muztagh Ata, Aconcagua, Elbrus and Kilimanjaro (twice). Closer to home, he has twice completed the Welsh 3000s.
Here's a summary of recent cases that we've been working on.
A landmark dispute in which HMRC classified accountancy provider Boox as a Managed Service Company Provider, triggering retrospective PAYE and National Insurance demands against thousands of contractors. JMTI is representing a contractor company in challenging HMRC's determination and defending its independent tax status.
The Loan Charge targets disguised remuneration schemes, in which loans were paid instead of salary to avoid Income Tax and National Insurance. Retrospective in effect and independently reviewed in 2025, it remains one of HMRC's most contested areas. JMTI is representing a client in ongoing dialogue with HMRC and an application to the First-tier Tax Tribunal challenging the liability.
Private Residence Relief exempts the gain on the sale of a person's main home, but disputes often turn on questions of fact, such as periods of absence or whether a property was genuinely occupied as a residence. JMTI is using Alternative Dispute Resolution to pursue a high-value, historic claim rejected by HMRC.
Code of Practice 8 (COP8) is used by HMRC's Fraud Investigation Service to examine suspected avoidance where fraud is not alleged, often involving complex offshore structures. JMTI is guiding a client through a COP8 voluntary disclosure of a historic offshore avoidance scheme, working toward an agreed settlement.
HMRC initially rejected a claim for historic trading losses. JMTI provided supporting evidence and detailed calculations, and HMRC's decision was subsequently overturned at independent review, securing the client a substantial six-figure reduction in their tax liability.
Section 34(1)(a) ITTOIA 2005 allows a deduction only for expenses incurred wholly and exclusively for the purposes of the trade. JMTI is using Alternative Dispute Resolution to represent a client in a dispute over the application of this rule, working with HMRC toward an agreed position on the expenditure.
Whether a worker is self-employed or an employee depends on the reality of the relationship, not the label in the contract. JMTI reviewed a company's historical arrangements with two contractors, concluded that they should have been employees, and made an unprompted voluntary disclosure to HMRC, placing the company in the strongest position to mitigate penalties.
Where HMRC considers that a payment from a registered pension scheme falls outside the permitted rules, it can charge the recipient tax of up to 55% on the payment. JMTI was engaged to give an independent opinion on the prospects of success of an appeal to the First-tier Tax Tribunal against such a charge.
Enquiries are treated in confidence. Get in touch and JMTI will get back to you.