Purple chairs in reception with a peek into the docks.

Tax investigations and dispute resolution

Our market-leading tax investigations and dispute resolution team is led by Partner, Adam Craggs, who has over 30 years' experience in contentious tax.

All the senior members of the team have experience of working within HM Revenue & Customs (HMRC). That experience delivers a unique blend of regulatory and commercial expertise and enables us to provide a comprehensive service covering pre-emptive advice on a wide range of risk issues, tax investigations and litigation before the tax tribunals and higher courts.

Dealing with tax risk and tax disputes is a specialist area demanding a high degree of expertise which is not readily available in most professional service practices. Interacting with HMRC on complex tax issues is time-consuming and stressful. We help FTSE 100 and multinational corporations, privately-owned businesses, and high-net-worth individuals manage that process. Where necessary, we collaborate with accountants, tax advisers and tax investigation practitioners, who regularly turn to us for specialist advice and assistance.

Our award-winning team includes former senior members of HMRC's Solicitor’s Office as well as lawyers who have many years of experience in the private sector. We understand how HMRC operates, what strategies it uses during investigations and in litigation, and how to secure the best settlements. Where a dispute has arisen, we steer our clients through what can be a complex and difficult process to the right 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