Specialist Advice From the Beginning

Proactive Consultancy Group was established in 2007 with a clear objective: to provide specialist tax advice in situations where detailed technical analysis could materially change the outcome for a business.

From the outset, our focus was not on becoming a generalist accounting practice.

We wanted to work on tax matters where understanding the legislation, the commercial arrangements and the underlying facts could make a significant financial difference for the client.

Over time, our work increasingly developed around complex VAT recovery, historic tax reviews and disputes with HMRC.

As our experience grew, so did the complexity and scale of the matters entrusted to us.

Today, more than £120 million has been recovered from HMRC for our clients, alongside multi-million-pound additional savings achieved through successful technical challenges and reductions in liabilities.

At the same time, the wider Group has expanded internationally, developing specialist tax advisory operations in Canada, the United Kingdom and Ireland.

This broader platform allows us to combine specialist local knowledge with the resources, systems and experience of an international advisory organisation.

Part of an International Tax Advisory Group

Proactive Consultancy Group is the UK specialist tax advisory business within a wider international group focused on complex tax incentives, indirect taxation and specialist advisory work.

In Canada, the Group operates Canadian SR&ED, a leading specialist consultancy focused on the Scientific Research and Experimental Development programme and other innovation-related tax incentives.

In Ireland, the Group operates through NX Advisory, providing specialist advisory services in relation to Irish R&D tax incentives and associated tax matters.

This international presence gives the Group experience across different tax systems, industries and commercial environments while allowing each business to maintain a clear specialist focus within its own jurisdiction.

For Proactive Consultancy Group, that focus remains firmly centred on complex UK VAT matters, HMRC disputes and high-value tax recovery opportunities.

The Group’s operations are headquartered in Calgary, Alberta, supported by satellite offices in:

Vancouver
Toronto
London
Dublin

Built Through Complex Cases

Much of our experience has been developed by working on matters where the answer was not immediately obvious.

We have advised businesses where HMRC had already reached an adverse technical conclusion.

We have reconstructed years of historic VAT records where the original calculations were incomplete or inconsistent.

We have examined modern healthcare and diagnostic services that did not fit neatly within traditional VAT models.

We have analysed principal and agent relationships, partial exemption methodologies, international transactions, import VAT and historic compliance failures.

We have also managed lengthy HMRC reviews requiring extensive technical submissions, detailed evidence and repeated engagement before a matter could be resolved.

Each of these cases adds to the body of experience we bring to the next engagement.

When the Position Is Complex

VAT treatment cannot always be determined simply by looking at an invoice or accounting entry.

The correct position may depend on much deeper questions.

  • Who is actually making the supply?
  • Is the business acting as principal or agent?
  • Is there one supply or several?
  • What is the principal purpose of the service?

In high-value matters, the answers to these questions can alter the tax position by hundreds of thousands or even millions of pounds.

Our approach is therefore to understand the transaction first and determine the tax treatment second.

  • Who is the true recipient?
  • Does a healthcare service meet the statutory conditions for exemption?
  • How should expenditure be attributed under partial exemption?
  • Does the accounting treatment reflect the legal and commercial reality of the transaction?

Challenging HMRC Where Necessary

We believe in constructive and professional engagement with HMRC.

However, an HMRC officer’s initial interpretation is not necessarily the final answer.

Where our technical analysis indicates that a different treatment is appropriate, we are prepared to challenge the position.

That may involve detailed submissions, analysis of legislation and case law, review of contractual arrangements, reconstruction of historic transactions and the preparation of extensive supporting evidence.

Some matters are resolved relatively quickly.

Others require multiple rounds of correspondence and sustained technical engagement.

Our objective is not simply to advance an argument. It is to establish a position that is technically sound, supported by evidence and capable of withstanding scrutiny.