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Tax & VAT Disputes

Contentious & non contentious

The Government is taking an increasingly hard line on tax avoidance and evasion and non-compliance. In 2015, HM Revenue & Customs (HMRC) was given a target to increase the number of criminal investigations into tax crimes by 2020. The pressure has led to an investment of an additional £1.8bn to tackle the complex and serious cases. As a result, an increasing number of individuals and businesses are being subject to tax investigations and significant tax demands.

HMRC has a number of weapons in its armoury to tackle the UK's tax gap which is estimated at £37bn. These include inspection powers and a penalties regime where businesses and individuals can be required to pay up to or, more than 100% of the tax payable. The financial implications for those subject to a tax dispute with HMRC is considerable and serious.

Our technical tax experts bring a deep understanding of the legal world of tax, tax authority governance, procedural knowledge and these skills are blended with our dispute experts who have a strong history in litigation and the resolution of tax disputes. Together our team has the right balance of skills to successfully take on complex cases to the Tax Tribunal, Court of Appeal, judicial review in the High Court and Court of Justice of the European Union.

Our integrated team work closely together and are able to support and advise both business and private clients innovatively and efficiently as they navigate what can seem like a tsunami of complex and challenging contentious tax matters.

Our considerable experience of the tax system enables us to advise on the strategy and procedures for negotiating settlements with HMRC and the process for conducting tax-related litigation including claims against professional advisors in relation to claims of negligent tax advice.

Dealing with tax disputes and litigation is a specialist area. Our tax disputes team work closely with our clients on each case to explore the full scope of matter, recognising that no two cases are the same, and advise on the best and most suitable way to resolve the dispute.

Representative matters we have worked on include:

  • Advising on dispute between HMRC and a taxpayer in respect of his VAT liability, making an application to the Court of Appeal to re-open the appeal process, despite the Court of Appeal having refused an application for permission to appeal.
    Advising on six judicial review applications in which the taxpayers, on a collective basis, are challenging notices served by HMRC for an account payment. Between July 2014 and April 2017, HMRC issued 60,000 such notices. It is estimated that HMRC has collected £3bn from taxpayers who have chosen to pay the sums demanded. The balance that is uncollected is estimated to be in the billions of pounds.
  • Advising film finance clients on responding to HMRC requests for documentation in cases of suspected fraud.
  • Assisting film finance clients on HMRC investigations into tax-driven partnership schemes.
    Advising the owners of The Three Graces by Antonio Canova on an HMRC investigation in relation to its offshore holding structure.
  • Successfully negotiating a VAT refund of several hundred thousand pounds for Marsh Farm Community Development Trust which ensured its survival.
  • Advising a high-net worth individual in relation to an HMRC investigation in respect of the offshore holding structure for his principal private residence which was put in place to minimise stamp duty land tax.
  • Advising an individual regarding reclaiming overpaid inheritance tax wrongfully imposed by HMRC in respect of the foreign bank account of his non-UK resident deceased brother.
  • Dealing with all aspects of disputes from enquiry to tribunal in respect of capital allowance claims in respect of Business Premises Renovation Allowance (BPRA) and E2S relief.