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Tax enquiries and disputes

Our team provides clear guidance to companies and individuals in relation to tax enquiries and disputes, at all stages of tax investigations.

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Overview Services Our team Our work What others say Insights

An HMRC enquiry or investigation can have a serious impact on a business or an individual, taking up time and resources with financial and reputational consequences.

Our tax disputes lawyers are sensitive to these issues and strive to accomplish the most practical and cost-effective solutions for our clients.

Our skilled team advises both corporate clients and high-net-worth individuals on tax disputes, frequently involving international issues. We handle everything from initial enquiries to fraud investigations, and from first-tier tribunal cases to high-value litigation at all levels.

In many cases, enquiries can be resolved through open communication and by providing the correct information to allow the relevant tax authority to carry out an efficient review. We regularly assist clients with the early stages of disputes with HMRC or other tax authorities, including dealing with initial enquiries and making voluntary disclosures.

With a sound understanding of HMRC’s litigation and settlement strategy, we take a strategic approach to resolving complex tax issues.

We are adept at negotiating with HMRC and using ADR as a method of resolving tax disputes to avoid litigation wherever our clients wish to do so. We also provide robust litigation support to our clients when the circumstances demand it.

As well as disputes with HMRC or other tax authorities, our tax disputes lawyers have experience acting on claims against tax advisers and on contractual claims under tax warranties and indemnities, as well as providing specialist support to other advisers.

We often work alongside other tax advisers to offer a comprehensive service, helping our clients to stay compliant and avoid potential disputes in the first place.

From civil enquiries to judicial reviews, our tax enquiries and disputes team offers comprehensive support and guidance tailored to your needs.

Services

Tax authority enquiries, discovery assessments and investigations under COP9

Appeals to the First and Upper Tier Tax Tribunals

Penalty assessments and appeals

Claims under tax warranties or indemnities

Responding to accelerated payment notices and follower notices

Alternative dispute resolution, including facilitation and mediation

Judicial review

Voluntary disclosures

Negligence actions against tax advisers

Fraud investigations

Our team

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Examples of our work

Lavinia Frances Corbally-Stourton v HMRC, SPC 00692

We led a landmark case at first instance, setting a precedent for when HMRC can issue discovery assessments, now widely cited in subsequent tax dispute cases.

Non-domiciled entrepreneur

We represented a non-domiciled individual entrepreneur in an HMRC enquiry into a consultancy arrangement, navigating complex cross-border and transfer of assets abroad issues to achieve a satisfactory resolution.

Purchaser of a company

Acting for a purchaser in relation to a tax indemnity claim relating to incorrectly claimed Coronavirus Job Retention Scheme payments.

Employer

Acting for an employer in an employment tax status dispute with HMRC, achieving a successful outcome for our client before the case went to tribunal. 

Construction party

Acting for the employer under a construction contract in relation to a dispute relating to the tax treatment of contract payments.

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What others say

“The team provides a real credible alternative to Magic Circle.”

Legal 500 UK 2024

“Burges Salmon respond quickly and attentively to queries and always answer questions clearly and concisely.”

Chambers UK 2024

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Insights

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