• Services we provide banner

    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."

Legal 500 UK, 2025, Tax Litigations & Investigations

Hugh Gunson, technically brilliant but with a keen eye on strategy."

Legal 500 UK, 2025, Tax Litigations & Investigations

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."

Legal 500 UK, 2025, Tax Litigations & Investigations

Charles Russell Speechlys offers the gold standard of service and capability when it comes to complex and sophisticated technical matters."

Chambers High Net Worth 2024, Tax: Private Client

Meet our tax disputes & investigation lawyer

Related pages

Private Wealth Disputes

Private Wealth Disputes

We provide tailored solutions for all varieties of domestic and international disputes for families and private wealth professionals. 

Find out more
Family Office Legal Services

Family Offices

For wealthy families looking to set up a family office.

Find out more
International Wealth Structuring Legal Services

International Wealth Structuring

We advise international individuals, and their trustees and advisers, on the establishment and administration of asset holding structures.

Find out more
Mental Capacity & Court of Protection Legal Services

Mental Capacity & Court of Protection

For those preparing documents to help protect finances and welfare when you no longer have the capacity to act.

Find out more
Philanthropy Legal Services

Philanthropy

For philanthropists and sustainable investors.

Find out more
Private Property Legal Services

Private Property

For those with personal property assets or those looking to purchase them.

Find out more
Reputation Management Lawyers

Reputation Management

Our team of experienced media dispute specialists is highly attuned to advising private individuals on ‘reputation management’ issues.

Find out more
UK Trust Establishment, Administration & Taxation Lawyers

UK Trust Establishment, Administration & Taxation

For those wishing to utilise trust structures and the administration of this.

Find out more
UK Wealth Structuring Legal Services

Wealth Structuring

For those wishing to draft a Will to distribute their assets through efficient structures.

Find out more
emma-johnson

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.

Contact us

Our thinking

  • Property118 schemes for landlords – a mistake worth fixing?

    Hugh Gunson

    Insights

  • An exceptionally harsh judgment? Exceptional circumstances revisited

    Dominic Lawrance

    Insights

  • 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

  • FT Ignites Europe quote Dominic Lawrance on the use of the UK's remittance basis

    Dominic Lawrance

    In the Press

  • Hugh Gunson and Guy Bud write for Taxation on partial closure notices

    Hugh Gunson

    In the Press

  • Hugh Gunson and Guy Bud write for LexisPSL on foreign currency mortgages and UK capital gains

    Hugh Gunson

    In the Press

  • Taxes On Wealth – The Global Landscape

    Matthew Radcliffe

    Insights

  • 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

  • A better alternative just around the block?

    Hugh Gunson

    Insights

  • 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

  • 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

  • Don’t Follow Me: Haworth and Follower Notices in the Supreme Court

    Hugh Gunson

    Insights

  • Northern Light: Illuminating IR35

    Hugh Gunson

    Insights

  • Tooth v HMRC: Getting to the Root of the Discovery Assessment Regime

    Hugh Gunson

    Quick Reads

  • Danish tax authority loses "cum-ex" case: revenue rule reigns supreme

    Hugh Gunson

    Insights

  • Hugh Gunson and Guy Bud write for Taxation on Financial institution notices

    Hugh Gunson

    In the Press

  • Property Patter: The Spring 2021 Budget – what news for property?

    Emma Humphreys

    Podcasts

  • 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

  • Loose Women presenter wins IR35 appeal

    Hugh Gunson

    Quick Reads

  • 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

Back to top