Tax Investigations and Disputes

We represent individuals and corporates involved in tax investigations and disputes across both direct and indirect tax.

Our work includes advising at all stages of an investigation and we have seen success at all levels of the English courts and in settlements and arbitrations for UK and non-UK clients. We cover matters including:

advising in relation to enquiries from HMRC and risk review checks;
negotiating settlements with HMRC, including by means of formal alternative dispute resolution;
defending challenges by HMRC to our clients’ tax positions at all levels of the courts;
assisting clients in implementing on-going tax compliance and governance structures;
assisting in relation to regulatory investigations;
holding HMRC and other regulatory bodies to account by means of judicial review;
advising in relation to criminal tax matters or where penalties are being sought;
assisting in relation to cross-border investigations, enquiries and challenges, including international arbitrations and mutual agreement procedures; and
advising on matters of professional negligence.

We draw on a wide range of expertise with members of our team including tribunal judges and CEDR accredited mediators, as well as former senior HMRC employees and policy officials.

Our expertise is combined with specialist knowledge across all tax practices, including corporate tax, personal tax, VAT, employment tax and real estate to ensure that we are able to achieve the best outcomes for our clients.

Recent work

A FTSE 100 company

Successfully resisting claims against a FTSE 100 company by way of a group litigation order involving approximately 300 claimants, with respect to the VAT treatment of certain supplies and their compliance with EU law.

Judicial review

Bringing a judicial review challenge (which has now been determined in the taxpayer’s favour) and substantive appeal with respect to HMRC’s approach to the taxation of certain Enterprise Zone arrangements.

Tax Tribunal appeal

Successfully appealing at the Tax Tribunal, a claim by HMRC against a high net worth individual that he was resident for tax purposes in the UK.

Advising on claims raised by HMRC

Advising a number of firms on various claims raised by HMRC with respect to the taxation of management fees, the application of the salaried member rules and the mixed member rules and the taxation of remuneration arrangements more generally.

A multinational group

Advising a multinational group with respect to matters concerning transfer pricing and the application of the diverted profits tax.

See all

Related contacts

See all contacts

Gideon Sanitt

Partner

+44 (0)20 7849 2123 Email Gideon

Gregory Price

Partner

+44 (0)20 7849 2754 Email Gregory

What people are saying

"They represent the premium service for clients in terms of technical matters. When a client uses them, the advice is so comprehensive and clear. I love working with them; I know I'm dealing with a lawyer who will have thought of everything, and it is very rare to see them make mistakes. They're technically gifted, and they work incredibly hard."

Chambers HNW 2023