CRG5225 - Financial redress: Reasonableness of professional fees
Source: gov.uk (2025-10-17)


Many customers hire accountants or other agents such as solicitors to deal with their tax affairs. The arrangements between customers and their agents are personal and should not be judged. Whether a customer has an agent or not doesn't affect the quality of service they should receive, and we should ensure all customers are treated fairly regardless of whether or not they employ a professional agent.

Customers can claim reimbursement of costs they have paid, including fees they have paid to their professional agents, if they are additional costs as a direct result of our mistake or unreasonable delay. However, before we reimburse, we need to consider whether it is right to do so.

We do not pay for “day-to-day” costs that an agent would charge in performance of the tasks they are employed to undertake. Even if something is incorrect, providing we put things right straightaway, at the first point of contact, it can be considered a day-to-day cost.

Professional fees vary for many reasons such as location of the firm, the level of expertise or specialism offered, and the level of the person within the firm carrying out the work.

You need to consider what is reasonable to reimburse. This may or may not be the full amount customers have paid. Make a judgement, based on the merits, circumstances and complexity of each case.

Make sure that the fees you are considering relate only to additional work carried out as a direct result of our mistakes or unreasonable delay.

Also, ask yourself these questions:

• does the customer usually use this agent?

• was the additional work done at a different level within the firm and at an appropriate level?

• was the work done at the usual hourly rate and is evidence of this available, if required, by way of invoices and/or timesheets?

• has the invoice been paid? We can ask for evidence of payment if we are not satisfied.

While a professional agent’s charges are a matter between agent and client, you are entitled to consider whether it is reasonable to reimburse all the charges invoiced. Reimbursement should be limited to what you consider to be reasonable and proportionate in all the circumstances, using your best estimate, where appropriate.

Do not be afraid to ask for further information you think is necessary but remember that every letter may increase costs for the customer and HMRC. In many cases it will be impossible to arrive at a precise figure with which both sides are happy. It will usually be best in such cases to pay what you think is reasonable and explain your reasoning. Depending on the particulars of the case, it may not be appropriate to question relatively small amounts in relation to the overall amount claimed.

Please note:
- Even if a complaint is fully upheld, it does not necessarily follow that we will reimburse all additional costs claimed.
Consider:
- Proportionality. Was there a financial impact? Costs of £5,000 to dispute a tax matter of £500 should be questioned.
- Has the agent or customer contributed to the issue that meant some costs are unreasonable or excessive?
- Did the agent self-serve? Did the agent use the appropriate contact point within HMRC? Was the matter relatively straightforward where we would expect an agent to resolve without the need to complain or continue with their complaint
- When was the matter corrected? Has the agent continued to contact us over minor issues, despite the customers affairs being in order?
- Has the agent invoiced their client for long times on hold waiting to get through to HMRC? We would reasonably expect professional agents to multitask and attend to other work while on hold.
For Audit purposes, it is important to record our rationale if we are not paying all costs claimed, particularly if the complaint escalates.

Providing your decision is reasonable in all the circumstances, whether at Tier 1 or Tier 2, you should not expect it to be overturned.

If you have a particularly difficult case that you need support with, contact CCAST.