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 detailed knowledge of the UK tax legislation, a thorough understanding of legal process in relation to tax disputes, including the statutory limits on HMRC’s powers, and practical insights into how HMRC fight and settle tax cases. 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, from private individuals, family businesses and trustees, through to entrepreneurs and corporates, both small and large. We are capable of advising on disputes relating to the most complex areas of personal and corporate taxation, for example the remittance basis, employee benefit trusts, offshore trusts and other non-resident structures, tax planning arrangements for both corporates and individuals, complex remuneration and incentive structures, diverted profits tax and 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.
Our work frequently also involves other contentious work with a tax aspect. This includes remedying unsuccessful planning (often involving complex trust arrangements), tax-related professional negligence claims against advisers and tax-related commercial disputes.
News & Insights
Hugh Gunson and Thomas Klemme write for Trusts and Trustees on cross-border enforcement of tax debts
Dominic Lawrance and Hugh Gunson write for Trusts & Estates Law and Tax Journal on dealing with HMRC enquiries and assessments into domicile
How to manage a domicile enquiry
Hugh Gunson considers how to approach a domicile enquiry from HMRC.