We have many years’ experience of tax disputes across the whole of the tax system; for clients from FTSE 100 companies to private individuals; for disputes involving multiple billions down to disputes over tens of thousands; and for all types of disputes, from international structuring to ‘traditional’ civil enquiries, criminal enquiries and interviews under caution.
We settle – often on extremely advantageous terms – the vast majority of the disputes we are instructed on. Where settlement is not possible, we litigate, and have considerable successful experience of doing so at all levels, from the First-tier Tribunal to the Court of Justice of the EU.
We advise individuals and companies of all sizes on disclosures to HMRC in circumstances where there is an ongoing HMRC enquiry, including under Code of Practice 8 and Code of Practice 9, the Contractual Disclosure Facility and Liechtenstein Disclosure Facility.
We advise alongside big four accountancy firms in large scale civil settlements with HMRC, and represent regulated individuals in interviews under caution conducted by HMRC – both where the individual has been arrested and where they have not.
We also conduct representative litigation before the tax tribunals in respect of investments that HMRC argues to be tax avoidance schemes.
Notable deals / highlights
Most of our matters are settled without recourse to any open forum, and thus remain confidential. However, the following indicate the breadth of the recent experience of our tax disputes partners:
Advised on group litigation against HMRC for restitution of tax overpaid in circumstances where UK tax rules breached EU freedoms.
Assisted a business during a search and uplift operation under warrant at its offices.
Represented a firm of accountants in a successful Judicial Review of the HMRC decision to refuse to deal with the firm as a tax agent in circumstances where HMRC alleged that the accountants had helped clients evade £116m of taxes.
Conducted an internal investigation for a listed company into whether the company had actual or constructive knowledge of fraud, as HMRC alleged, in respect of an input tax reclaim that had been denied.