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. We provide specialist advice to guide you through what can be a complex and stressful process.

Whether you are a private individual, family business, trustee, entrepreneur or corporate, both small and large, we can assist you with tax disputes and investigations. We have experience advising on disputes relating to the most complex areas of personal and corporate taxation, including:

• 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. 

You may also find yourself impacted by any of the full range of UK taxes, both direct and indirect, including income tax, CGT, corporation tax, inheritance tax, SDLT and VAT. Our large personal and corporate tax teams have the expertise to advise you on all of these areas as well as any issues with a cross-border element, where we regularly work in collaboration with other professional advisers both in the UK and overseas.

Should you find yourself subject to an HMRC investigation, we will work with you to understand your issues fully and manage the investigative process. We always seek to achieve the best outcomes for you and adapt our strategy to the specific needs of each case. Achieving a negotiated settlement where possible would be our preferred option for you. However, where necessary, we are fully prepared to take cases to litigation 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.

We also provide preventative advice, assessing tax risk concerning proposed or existing arrangements and giving guidance on mitigating it.