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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.
Our awards
In a very specialist area, this is a team that really knows what it is doing. Top class."
Hugh Gunson, technically brilliant but with a keen eye on strategy."
The great advantage of Charles Russell Speechlys' tax team is, apart from their excellent expertise in field of tax litigation and investigations generally, their ability to draw also on the expertise of their also excellent private client departments."
Charles Russell Speechlys offers the gold standard of service and capability when it comes to complex and sophisticated technical matters."
Meet our tax disputes & investigation lawyer
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What's important to you is important to us. Let's talk
If you would like to speak to a member of our Dispute Resolution team or to find out more about how we work, please get in touch.
Our thinking
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An exceptionally harsh judgment? Exceptional circumstances revisited
Dominic Lawrance
Insights
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Hugh Gunson and Guy Bud write for the Tax Journal on the Court of Appeal’s recent judgment in Hoey
Hugh Gunson
In the Press
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FT Ignites Europe quote Dominic Lawrance on the use of the UK's remittance basis
Dominic Lawrance
In the Press
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Hugh Gunson and Guy Bud write for Taxation on partial closure notices
Hugh Gunson
In the Press
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Hugh Gunson and Guy Bud write for LexisPSL on foreign currency mortgages and UK capital gains
Hugh Gunson
In the Press
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Hugh Gunson and Guy Bud write for Tax Journal and LexisPSL on Double Tax Conventions with Guernsey and the Isle of Man
Hugh Gunson
In the Press
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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
In the Press
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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
Hugh Gunson
In the Press
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Don’t Follow Me: Haworth and Follower Notices in the Supreme Court
Hugh Gunson
Insights
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Tooth v HMRC: Getting to the Root of the Discovery Assessment Regime
Hugh Gunson
Quick Reads
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Danish tax authority loses "cum-ex" case: revenue rule reigns supreme
Hugh Gunson
Insights
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Hugh Gunson and Guy Bud write for Taxation on Financial institution notices
Hugh Gunson
In the Press
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Property Patter: The Spring 2021 Budget – what news for property?
Emma Humphreys
Podcasts
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Hugh Gunson and Guy Bud write for Tax Journal on the guidance provided by the Upper Tribunal in Atholl House
Hugh Gunson
In the Press
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Dominic Lawrance, Hugh Gunson and Catrin Harrison write for Tax Journal on Embiricos and the future of partial closure notices
Dominic Lawrance
In the Press