Tax Disputes & Investigations Lawyers

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 large corporate, we can assist you with tax disputes and tax investigations. We have experience advising on the most complex and serious HMRC investigations, involving the most complex areas of personal and corporate taxation, including:

• Corporate and individual tax residence (including under the statutory residence test (SRT));
• Domicile enquiries
• The remittance basis;
• Employee benefit trusts (EBTs);
• Offshore trusts and other non-resident structures;
• IR35 / off-payroll working and other employment tax issues;
• Tax planning arrangements and tax avoidance schemes for both corporates and individuals;
• Complex remuneration and incentive structures;
• Code of Practice 8 (COP 8) investigations;
• Code of Practice 9 (COP 9) investigations;
• Diverted profits tax (DPT);
• Cum-ex and cum-cum investigations; and
• Complex VAT issues, including VAT registration issues and input VAT recovery in multi-party contractual arrangements.

If you find yourself with any UK tax issue, whether relating to income tax, capital gains tax (CGT), corporation tax, inheritance tax, SDLT or VAT, we are here to help. We often work in conjunction with our large personal and corporate tax teams, who can also assist you with any other issues or planning going forwards.  Our work frequently has a cross-border element, and we regularly work in collaboration with other professional advisers both in the UK and overseas.

UK Tax investigation advice

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 prompt 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.  We have experience of running cases 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:

• Professional negligence claims against advisers for negligent tax advice;
• 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.