Purple chairs in reception with a peek into the docks.

Tax disputes

With our dedicated tax dispute lawyers, you'll benefit from a unique blend of HMRC and commercial experience.

HMRC’s approach to both corporate and individual taxpayers is focused on risk assessing and tackling non-compliance. HMRC is armed with wide-ranging information and inspection powers and a penalties regime which can lead to penalties of up to or more than 100% of the tax payable.

Dealing with tax risk and tax contentious work is a specialist area demanding a high degree of expertise which is not readily available in most professional practices. Interacting with HMRC on complex tax issues can be time-consuming and stressful for clients. We work with FTSE 100 and multinational corporations, privately-owned businesses, and high-net-worth individuals. We collaborate with accountants, tax advisers and tax investigation practitioners, who regularly turn to us for specialist assistance.

Our top-ranked team includes former senior members of HMRC's Solicitor’s Office who also have many years of experience in the private sector. We understand how HMRC operates, what strategies it may use in litigation, and how to secure the best settlements for our clients. Where a dispute has arisen, we are able to steer our clients through what can be a complex and difficult process to reach a successful outcome.

What we do

  • Assessing and mitigating tax risk

  • Advice on HMRC’s information powers

  • Advice on HMRC’s penalties regime

  • Handling HMRC enquiries and specialist investigations

  • Alternative dispute resolution – HMRC internal review; mediation

  • Challenges to HMRC’s conduct by way of judicial review in the High Court

  • Restitutionary and/or damages claims in the High Court

  • Court of Justice of the European Union

  • Criminal defence advice and representation in cases of alleged serious tax fraud, including COP9

  • HMRC “dawn raids”

Relevant work

  • Coca Cola Enterprises v HMRC – dispute in the Tax Tribunal over tax status of cars / vans

  • R (on the application of Newcastle United Football Company Ltd) v HMRC – judicial review of search warrants in the High Court

  • Sports Direct v HMRC – dispute over Tax Tribunal jurisdiction

  • R (on the application of De Silva and another) v HMRC – awaiting judgment from the Supreme Court

  • Dickinson v HMRC – judicial review challenge against issuance of Accelerated Payment Notices in the High Court

The Team