Specialist tax advisory support for individuals, limited companies and professional introducers. Expert representation in HMRC disputes, investigations and Loan Charge settlements.
Following Budget 2025, the government accepted the main recommendations of Ray McCann's independent review of the Loan Charge and announced a new settlement opportunity for those with outstanding liabilities.
HMRC has confirmed that it expects to begin writing to interested taxpayers from summer 2026, once the enabling secondary legislation is in place. The arrival of HMRC's settlement pack will trigger important and time-sensitive decisions.
I have particular expertise working with film scheme participants and other tax scheme arrangements, and am well placed to act as a specialist resource alongside your existing adviser.
If you or your client has received correspondence from HMRC regarding a Loan Charge or disguised remuneration scheme, do not respond without specialist advice. Deadlines can be short and the settlement arithmetic is rarely straightforward.
I offer an initial conversation in confidence and at no obligation.
Call 07855 835510Or email: joe_cotter_solutions@outlook.com
Beyond the Loan Charge, I offer specialist support across the full range of HMRC enquiry and compliance work — acting either as lead adviser or as a consultant working alongside your existing client relationship.
PAYE and NIC disputes including Disguised Remuneration challenges, EBT schemes and loan arrangements. Robust technical representation.
Corporation Tax and Income Tax enquiries. Code of Practice 8 and 9 cases, Fraud Investigation Service and all HMRC compliance checks.
Discovery assessments and closure notice applications. Challenging HMRC's entitlement to raise assessments and establishing time limits.
Penalty appeals, reasonable excuse arguments and full representation at First-tier and Upper Tribunal proceedings where settlement cannot be agreed.
Preparing and submitting voluntary disclosures to HMRC. Securing the best possible terms and minimising penalty exposure for clients coming forward.
HMRC correspondence, compliance matters, information requests and inspection powers. Practical, proportionate support at every stage.
Many general accountancy practices have clients who become subject to HMRC enquiries, Loan Charge demands or wider tax disputes — areas that fall outside day-to-day compliance work and can be time-consuming and technically complex.
I work alongside existing client relationships, acting as a specialist resource without displacing the primary adviser. You retain the client relationship; I provide the technical expertise.
FCCA · Principal, Cotter Solutions
My name is Joe Rayner and I am the principal of Cotter Solutions (a trading name of CS ET ALIA LIMITED), a specialist tax advisory firm with particular expertise in HMRC disputes, tax investigations and Loan Charge matters.
I work with a number of clients who are participants in various tax schemes and have developed a detailed and practical understanding of the issues arising from those schemes specifically, as well as the wider Loan Charge landscape. I am currently working with a number of film scheme participants and am well placed to act as specialist resource for this type of case.
The firm works with individuals, owner-managed businesses, high-net-worth clients and professional introducers — particularly accountancy practices who encounter HMRC enquiry issues outside their everyday compliance work.
I am able to act either as lead adviser, taking full responsibility for the matter, or as a consultant working discreetly alongside your existing adviser relationship. My aim is always to achieve the best available outcome as efficiently as possible, with clear communication at every stage.
Live news and official tribunal decisions — updated automatically.
Browse and search the Taxes Management Act 1970 — the primary procedural statute governing HMRC's powers of enquiry, assessment, appeal, and collection. Content is sourced directly from legislation.gov.uk.
All initial discussions are in confidence and at no obligation. Whether you are an individual with a Loan Charge demand, an accountancy practice looking for a referral partner, or anyone facing an HMRC enquiry, I am happy to talk.