One minute with Tom Wallace, Director at WTT Consulting.
What’s keeping you busy at work?
A mixture of disputes work is on my desk at the moment, but we are seeing a particular rise in the content creator space and the gig economy. With HMRC having access to increasingly large data sets, it has become easier for them to identify those in the hidden economy.
What do you know now that you wish you’d known at the start of your career?
A strong technical foundation is important, but the people who have the most successful careers in tax combine that with sound judgement, good communication and commercial awareness. It’s important to say yes to as many opportunities as possible, especially if it takes you out of your comfort zone, as that is how you will build those skills. Tax is a people business, whether that’s when dealing with clients or your internal teams.
If you could make one change to tax law or practice, what would it be?
It’s not really a change to tax law or practice, but I would improve tax education. People are expected to leave education and engage with the tax system without being taught the basics of a payslip, how a tax code works or the difference between employment and self-employment. A better understanding would prevent confusion, poor decisions and would avoid many of the problems we see before they arise.
What is the biggest mistake you see HMRC making in enquiries? And where do advisers often go wrong?
Poorly targeted information requests are a common weakness – with HMRC asking for large amounts of generic information rather than focusing on the risks, or indeed even asking for information that is not relevant to the year under review or is in the hands of an entirely separate party. Advisers inexperienced with the enquiry framework will often accede to these requests when HMRC have no legal basis, which can not only cause the enquiry to become unfocused but also could be a professional negligence claim waiting to happen!
Any new trends you’re seeing in tax?
The direction of the tax advice market is shifting, with an increasing regulatory focus on advisers as well as taxpayers. Mandatory tax adviser registration and the new sanctionable conduct regime in FA 2026 will require the profession to engage quickly with a materially different compliance landscape.
The underlying policy rationale is clear. However, both regimes adopt wide definitions of ‘tax adviser’ and ‘sanctionable conduct’. They are not confined to the most egregious behaviour and may extend to anyone involved in tax matters.
Advisers should therefore take steps now to understand the scope of these regimes and their potential exposure, given the seriousness of the associated sanctions and penalties.
Has a recent tax case caught your eye?
Yes, Witton v HMRC [2026] UKFTT 267 (TC) – not necessarily for the technical points at issue, but rather for HMRC’s failure to advise the court and the appellants that one of their witnesses would not be attending tribunal, despite being made aware of this some six months earlier. The judge rightly was critical of this. It is a reminder that the duty to cooperate with the tribunal is not optional – even where it damages your own case.
And finally, you might not know this about me but...
I used to play poker to a decent standard and even appeared at the World Series of Poker in Las Vegas. Both tax disputes and poker involve risk, strategy and reading the other side – so it’s debatable which one made me good at the other!
One minute with Tom Wallace, Director at WTT Consulting.
What’s keeping you busy at work?
A mixture of disputes work is on my desk at the moment, but we are seeing a particular rise in the content creator space and the gig economy. With HMRC having access to increasingly large data sets, it has become easier for them to identify those in the hidden economy.
What do you know now that you wish you’d known at the start of your career?
A strong technical foundation is important, but the people who have the most successful careers in tax combine that with sound judgement, good communication and commercial awareness. It’s important to say yes to as many opportunities as possible, especially if it takes you out of your comfort zone, as that is how you will build those skills. Tax is a people business, whether that’s when dealing with clients or your internal teams.
If you could make one change to tax law or practice, what would it be?
It’s not really a change to tax law or practice, but I would improve tax education. People are expected to leave education and engage with the tax system without being taught the basics of a payslip, how a tax code works or the difference between employment and self-employment. A better understanding would prevent confusion, poor decisions and would avoid many of the problems we see before they arise.
What is the biggest mistake you see HMRC making in enquiries? And where do advisers often go wrong?
Poorly targeted information requests are a common weakness – with HMRC asking for large amounts of generic information rather than focusing on the risks, or indeed even asking for information that is not relevant to the year under review or is in the hands of an entirely separate party. Advisers inexperienced with the enquiry framework will often accede to these requests when HMRC have no legal basis, which can not only cause the enquiry to become unfocused but also could be a professional negligence claim waiting to happen!
Any new trends you’re seeing in tax?
The direction of the tax advice market is shifting, with an increasing regulatory focus on advisers as well as taxpayers. Mandatory tax adviser registration and the new sanctionable conduct regime in FA 2026 will require the profession to engage quickly with a materially different compliance landscape.
The underlying policy rationale is clear. However, both regimes adopt wide definitions of ‘tax adviser’ and ‘sanctionable conduct’. They are not confined to the most egregious behaviour and may extend to anyone involved in tax matters.
Advisers should therefore take steps now to understand the scope of these regimes and their potential exposure, given the seriousness of the associated sanctions and penalties.
Has a recent tax case caught your eye?
Yes, Witton v HMRC [2026] UKFTT 267 (TC) – not necessarily for the technical points at issue, but rather for HMRC’s failure to advise the court and the appellants that one of their witnesses would not be attending tribunal, despite being made aware of this some six months earlier. The judge rightly was critical of this. It is a reminder that the duty to cooperate with the tribunal is not optional – even where it damages your own case.
And finally, you might not know this about me but...
I used to play poker to a decent standard and even appeared at the World Series of Poker in Las Vegas. Both tax disputes and poker involve risk, strategy and reading the other side – so it’s debatable which one made me good at the other!
.tmb-editorspic.jpeg?sfvrsn=7981419_1)
