Tax Disputes and Investigations

VAT disputes

Including single/multiple supplies, scope of exemptions, and zero-rating. If you are in receipt of an assessments, or have been issued with any penalties, we will help identify the correct steps in order to challenge HMRC where necessary.

Employment related taxes/HMRC issues

1 .IR35/’off-payroll working rules’: Questions relating to a worker’s status are not easy and require a wider understanding of the relevant rules and practical insight as to how HMRC approach them. Working with your in-house HR function and together with our Employment team where necessary, we can support you through an enquiry or dispute.

2. National Minimum Wage disputes: With substantial penalties involved, we can advise on the HMRC’s strict interpretation of the rules, which have recently included advice relating to salary sacrifice schemes, uniform policies, and unpaid working time among others. We can work alongside your HR team to engage in a dialogue with HMRC at early stage before a matter proceeds into something more substantial requiring HMRC to issue/threaten to issue a Notice of Underpayment (which comes which significant penalties and ‘naming and shaming’ considerations).

3. COVID-19 support schemes: As HMRC raise enquiries into Covid-19 related support schemes, a robust and thorough consideration of how your business utilised the scheme in order to defend your position is crucial.

Residence and domicile enquiries

We act for clients at different procedural stages, and have the expertise in providing practical and strategically advice.

Other tax disputes

including income tax and NICs, Corporation tax, Capital Gains Tax, image rights disputes for sportspersons, customs and excise duty appeals, all areas of direct and indirect tax litigation, disclosures and judicial reviews.

HMRC criminal investigations and fraud

Working alongside our top ranked criminal litigation team, we can proactively anticipate issues and put our client in the best possible position. We have experience acting for clients subject to enquiry under HMRC’s Code of Practices 8 and 9 (COP8 and COP9), allegations of tax avoidance and tax evasion, as well as other similar offences such as the corporate offence of failure to prevent the facilitation of tax evasion.