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Tax Disputes & Investigations

We handle disputes and investigations for our clients across all areas of tax.

Engagement with HMRC is rarely straightforward, particularly when matters become contentious.  Effective management of tax disputes and investigations requires specialist expertise, in particular a thorough understanding of the legal process and HMRC’s powers, practical insights into how HMRC fight and settle tax cases, as well as detailed knowledge of the UK tax legislation.  Our team provides specialist advice to guide clients through what can be a complex and stressful process.

We specialise in handling tax disputes and investigations for all our clients, including private individuals, family businesses, trustees, entrepreneurs and corporates, both small and large.  We have experience of advising on disputes relating to the most complex areas of personal and corporate taxation, for example:

  • the remittance basis;
  • employee benefit trusts (EBTs);
  • offshore trusts and other non-resident structures;
  • IR35 and other employment tax issues;
  • tax planning arrangements and tax avoidance schemes for both corporates and individuals;
  • complex remuneration and incentive structures;
  • diverted profits tax (DPT); and
  • complex VAT issues, including input VAT recovery in multi-party contractual arrangements.  

A particular strength is the depth of expertise that we have within our large personal and corporate tax team.

Our work covers the full range of UK taxes, both direct and indirect; including income tax, CGT, corporation tax, inheritance tax, SDLT and VAT.  A significant proportion of our work in this area has a substantial cross-border element.  We regularly work in collaboration with other professional advisers both in the UK and overseas.

We advise on all aspects of the disputes process, including taxpayers’ rights, HMRC’s powers, public law aspects including judicial review, tax-related penalties, and the procedure for the specialist tax tribunals.  We also provide preventative advice, assessing tax risk in relation to proposed arrangements and giving guidance on mitigating it.

We always seek to achieve the best outcomes for our clients and adapt our strategy to the specific needs of each case.  We look to achieve a negotiated settlement where possible, drawing on our understanding of HMRC’s strategies and policy considerations.  This typically requires a creative approach to find a solution mutually acceptable to both the taxpayer and HMRC.  However, where necessary, we are fully prepared to take cases to litigation.  We have experience of doing so at all levels, from the specialist tax tribunals through to the Court of Appeal and the Supreme Court.  

A significant element of our work involves other contentious work with a tax aspect, including:

  • tax-related professional negligence claims;
  • tax-related claims for mistake and rectification, in both the UK and offshore jurisdictions;
  • remedying unsuccessful planning (often involving complex trust arrangements); and
  • tax-related commercial disputes.
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