Contentious Tax
Experts at resolving tax enquiries, investigations and disputes.
Contentious tax matters are complex, high-stakes, and disruptive. The number of tax authority challenges continues to rise as tax authorities take tougher action to maximise receipts. Taxpayers have never been under more scrutiny. In these circumstances, clients come to us because they know we have deep expertise and a track record of success.
We support corporates of all sizes, investment funds, managers, professional services firms and high-net-worth individuals. Our role includes negotiating with HMRC, resolving disputes before they escalate to litigation and, where litigation is necessary, managing the risks involved. We also provide specialist support in professional negligence matters.
Combining legal and tax expertise with commercial insight, we lead clients through the complex maze of tax enquiries, investigations and disputes. Where cases cross borders or require input from other legal disciplines, our collaborative approach ensures seamless, joined-up support.
Clients choose us for our strategic, outcome-driven advice. With leaders in the field guiding every step, clients gain peace of mind and a clear path forward.
Our Services
Advising clients across all sectors in relation to HMRC’s powers, including the risks of an enquiry or investigation being opened before such a process has begun and the circumstances in which clients are required to make a disclosure to HMRC or should consider making a voluntary disclosure.
Representing clients who are under enquiry or investigation by HMRC, including advising in relation to procedural matters and tactical considerations.
Where litigation or ADR is necessary, representing clients and advising them on process, timings, costs, risks and tactics.
We have deep expertise in contentious matters across the UK’s tax code. Examples include:
+ handling a highly complex case before the tribunals concerning capital allowances and leasing in the context of the UK’s specialist tonnage tax regime;
+ acting for a corporate client in a lengthy tax investigation concerning the application of the loan relationship rules for connected companies and the late-paid interest rules;
+ acting for a high-net-worth and high-profile individual in the context of a “code of practice 9” (COP 9) investigation which lasted for several years and covered a 20-year period;
+ taking a case up to the Court of Appeal concerning the availability of capital allowances in the context of launch costs for satellites;
+ advising an investment management firm on the application of the “disguised investment management fees” rules, including instructing counsel and preparing a complex “white space” disclosure to HMRC;
+ helping a corporate client to analyse its tax compliance position, make a voluntary disclosure to HMRC in relation to substantial underpayments of income tax and national insurance and managing the risks of interest, penalties and potential litigation;
+ acting for a public-sector client in a VAT dispute involving an appeal to the tribunal whilst also seeking to resolve a related dispute with a contractual counterparty;
+ acting for a high-net-worth individual in a long-running domicile dispute, including pursuing ADR with HMRC;
+ acting for a corporate client in a tax investigation concerning benefits-in-kind tax charges arising from a director’s access to high-value company assets for personal use; and
+ acting for a high-net-worth individual in a complex employment tax dispute concerning agents’ fees in the professional football context.
