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.
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 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.
FT Ignites Europe quote Dominic Lawrance on the use of the UK's remittance basis
FT Ignites Europe quote Dominic Lawrance on the UK's remittance basis regime
Hugh Gunson and Guy Bud write for Taxation on partial closure notices
Hugh and Guy examine the Court of Appeal’s decision in the Embiricos case and comment on practitioners’ views on how PCNs should act.
Hugh Gunson and Guy Bud write for LexisPSL on foreign currency mortgages and UK capital gains
The case is a reminder of the importance of tax implications, particularly where foreign currency amounts are involved.
Taxes On Wealth – The Global Landscape
How will new taxes on wealth affect your wealth management and structuring?
Hugh Gunson and Guy Bud write for Tax Journal and LexisPSL on Double Tax Conventions with Guernsey and the Isle of Man
From 1 January, provisions in the UK's DTAs with Guernsey and the Isle of Man on mutual enforcement and collection of taxes come into force.
A better alternative just around the block?
Hugh and Guy explain the experiences of startup Fashion on the Block after it inadvertently filed the wrong form with HMRC
Hugh Gunson and Guy Bud write for HMRC Tax Investigation on the experiences of Fashion on the Block after it inadvertently filed the wrong form with HMRC
Hugh Gunson and Guy Bud explain the experiences consider the High Court's decision in Fashion on the Block Ltd v HMRC.
Hugh Gunson and Guy Bud write for Taxation on the implications of the Court of Appeal's decision in CRC v Professional Game Match Officials Ltd
The unanimous judgment in the Court of Appeal will bring some clarity to the rules around mutuality of obligation and control.
Don’t Follow Me: Haworth and Follower Notices in the Supreme Court
Hugh and Guy look at Follower Notices and the recent Supreme Court case of R (Haworth) v Revenue and Customs Comrs
Information overlord? Are there limits on HMRC's power to require information from foreign domiciled taxpayers?
Hugh, Catrin and Dominic look at the decision in Perlman v HMRC. The latest decision where HMRC is challenging a taxpayer’s domicile
Northern Light: Illuminating IR35
Guy and Hugh take a look at the recent case of Northern Light Solutions Ltd v Revenue and Customs Comrs
Tooth v HMRC: Getting to the Root of the Discovery Assessment Regime
Danish tax authority loses "cum-ex" case: revenue rule reigns supreme
Hugh and Guy look at the recent decision in Skatteforvaltningen v Solo Capital Partners LLP (in special liquidation) and others
Hugh Gunson and Guy Bud write for Taxation on Financial institution notices
Amendments will be made to allow HMRC to request information for the purposes of collecting a taxpayer’s tax debt.
Hugh Gunson and Guy Bud write for Tax Journal on the guidance provided by the Upper Tribunal in Atholl House
The ‘intermediaries legislation’, commonly known as IR35, has proved an area of legal uncertainty and worry for taxpayers in recent years.
Loose Women presenter wins IR35 appeal
Dominic Lawrance, Hugh Gunson and Catrin Harrison write for Tax Journal on Embiricos and the future of partial closure notices
A look at the Upper Tribunal's decision in Embiricos and the implications for those faced with a domicile enquiry.