Tax disputes

Ranked in Chambers UK 2013 as one of the top tax litigation teams in the country, our specialist tax dispute resolution team comprises dedicated lawyers with a unique blend of regulatory and commercial experience. This enables us to provide a comprehensive service covering pre-emptive advice on tax risk issues, enquiries and investigations and litigation at the Tribunals and Higher Courts. We act on behalf of a broad range of clients, ranging from FTSE 100 companies and multi-national corporations through to privately owned businesses and high net-worth individuals.

We regularly work with other professional advisers such as accountants, tax advisers and tax investigation practitioners. Some of our work is referred to us by professional advisers who require specialist assistance in preventing or resolving disputes with the tax authorities on behalf of their clients.

Our team includes former senior members of Her Majesty's Revenue and Customs (HMRC) who also have many years of experience in the private sector. We know HMRC inside out; how they work and how to secure the best results for our clients.

• "Sources say this team is 'good at putting the client at ease and explaining the legal process to them.' Clients also appreciate RPC's lawyers' 'accessibility, both in terms of making themselves available for consultation, but also their manner, style and approach'" - Chambers UK 2013
• "RPC’s team has expert knowledge in GLO matters, and disputes involving HMRC" - The Legal 500, 2012 edition
• "Very switched on to things and always very calm to deal with" - Chambers UK 2012
• "First-rate legal knowledge... practical experience of HMRC’s internal workings" - The Legal 500, 2011 edition
• "This highly regarded team is recommended for its expertise in tax investigations, transfer pricing, EU discrimination concerns and compound interest claims against HMRC" - Chambers UK 2011
• "The team includes a number of former members of HMRC's Solicitors Office, giving it in-depth sector knowledge" - Chambers UK 2011
• "The team is ‘highly efficient and very capable’" - The Legal 500, 2010 edition
• "A great choice for contentious tax cases... The lawyers are praised for anticipating potential problems and for being quick to respond" - Chambers UK 2010
• "This small team of charming, sensible tax litigators really punches above its weight" - Chambers UK 2010
• "The lawyers here are known for 'providing straight-talking advice, rather than simply what the clients want to hear' and the team is considered 'great for tax disputes work" - Chambers UK 2009

Our areas of expertise include:

• Assessing and mitigating tax risk
• Enquiries and specialist investigations including information powers and penalties
• Alternative dispute resolution - mediation, HMRC internal review
• Tax tribunal hearings (First-tier Tribunal and Upper Tribunal)
• Appeals (Court of Appeal and Supreme Court)
• Restitutionary and/or damages claims and challenges by way of judicial review in the High Court
• European Court of Justice

Examples of relevant work

• Formulation of tax risk policies for a number of corporate clients
• Dealing with negotiations and settlement of issues arising during HMRC enquiries into a large corporate client including use of information powers and penalties
• Acting for large multinationals involved in all of the tax group litigation orders raising EU discrimination issues
• Dealing with a VAT issue for a major catering supplier in the High Court to a successful conclusion in the Court of Appeal
• Handling a complex transfer pricing dispute for a major retailer before the Special Commissioners
• Taking a case to the Court of Appeal on the issue of the relationship between statutory and common law remedies in tax
• Judicial review application on behalf of a high net worth individual in relation to a decision taken by HMRC

Funding Tax Litigation

• To read our guide to Funding Tax Litigation, click here.

Tax Appeals

• To read our Tax Appeals - Practical Guidance, click here.

Publications

• To read our Tax publications, click here.
• To read our Tax Blog, click here.
• To read Jonathan Levy's articles for Tax Journal, click here. To read his articles for Taxation, click here.
• To read Adam Craggs' articles for Tax Journal, click here. To read his articles for Taxation, click here.

Click here to read a speech given by David Gauke MP, Exchequer Secretary to HM Treasury, at the May 2011 meeting of the Tax Journal Breakfast Club, which is sponsored by RPC. This article is also available to view online for Tax Journal subscribers here.

For more information on our tax litigation practice, please contact Jonathan Levy (jonathan.levy@rpc.co.uk) or Adam Craggs (adam.craggs@rpc.co.uk)

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