A senior tax function on a fixed monthly retainer for UK businesses too big for compliance-only support but too lean to justify a full-time tax director. Board-ready memos, HMRC strategy, transfer pricing, M&A and group structuring — delivered by a Chartered Tax Adviser with an active Head of Tax — Europe role at a major digital infrastructure operator.
An Outsourced Head of Tax provides a senior tax function on a monthly retainer for UK businesses with revenue typically £5m–£50m. We attend management meetings, write board papers, lead HMRC engagement, oversee transfer pricing and group structuring, support M&A and audit deferred tax — at a fraction of the £150k+ cost of a full-time internal tax director. Typical retainers sit in the £2,500–£8,000 per month range.
There’s a gap in the UK tax services market. Below £5m of revenue, most businesses are well-served by their compliance accountant filing the CT600. Above £100m of revenue, an internal tax director or full Big-4 engagement makes sense.
In between — for mid-market businesses with group structures, international flows, M&A activity, R&D claims, share schemes, transfer pricing, deferred tax provisions, or live HMRC engagement — there is a real gap. The compliance accountant is too thin to sit with the board on strategy. A full-time Head of Tax costs £120k–£180k all-in and is hard to justify if the work is genuinely fractional. The Big-4 boutiques charge five-figure fees for individual projects with no continuity.
The Outsourced Head of Tax model fills this gap. You get a Chartered Tax Adviser embedded in your finance function on a fixed monthly retainer — proportional to the work needed, available when the board needs a paper, the auditors push back on a deferred tax position, or HMRC opens correspondence.
An engagement can be scoped narrow or broad depending on what you actually need. Typical scope items include:
Position papers on contentious or material tax matters — written for the board, the auditors, or HMRC. Defensible, referenced, and decision-ready.
Leading correspondence on enquiries, voluntary disclosures, settlement negotiations, technical clearances and ADR. Senior, deliberate, and on the front foot.
UK and international group reorganisations — subsidiary creation, holding company insertions, share-for-share exchanges, cross-border migrations. Tax-efficient, defensible, and aligned with commercial substance.
Buy-side and sell-side. Tax due diligence, deal structuring, SPA tax warranties, completion accounts mechanics, post-completion integration. Sat alongside your corporate finance adviser.
Master file, local file and country-by-country reporting where applicable. Inter-company agreements. Substance documentation. APA negotiation. Defending the policy under HMRC challenge.
Robust R&D claims under the merged scheme — qualifying activities analysis, technical narrative, costed boundary, and HMRC defensibility. Patent Box where the IP regime fits.
Tax accounting under FRS 102 / IFRS — deferred tax computation, effective tax rate analysis, uncertain tax positions, and direct engagement with the auditors at year-end.
EMI, CSOP, growth shares, employee ownership trusts, BADR planning. Director remuneration optimisation. Section 421 / employment-related securities housekeeping.
Engagements are deliberately structured to feel like an internal team member, not an external consultant. Typical mechanics:
If an Outsourced Head of Tax isn’t the right fit, these may be.
Anonymised summaries of representative OHT engagements. Each shows a real type of mid-market situation, the work delivered, and the outcome — without identifying the client.
Profile: £20m revenue · UK + 2 EU subsidiaries · 18-month engagement
Profile: £50m portfolio · Family-owned group · Ongoing engagement
Profile: £15m revenue · 12-month exit horizon · Project engagement
All engagements anonymised to protect client confidentiality. Specifics of your situation will be discussed under our standard confidentiality terms during the discovery call.
Book a Free Discovery Call. We’ll talk through your business, your group, your live tax matters, and propose a retainer scope and fee — or recommend a different service if it’s the better fit.
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