Tax disputes & litigation
Tax disputes can be diverse in nature. Many do not reach a court or tribunal.
We have ever growing experience of VAT and direct tax disputes. For example we have:
- Advised clients on the prospect of appealing to the First Tier Tribunal (and its predecessors the Special Commissioners and the VAT Tribunal)
- Represented a client before the First Tier Tribunal in a successful appeal against a VAT default surcharge
- Been fully involved in taking a case from a Tribunal, via the High Court, to the Court of Appeal on behalf of a multinational company (initially putting forward the case to HM Revenue & Customs ("HMRC") and then involving Counsel as appropriate)
- Advised and assisted clients who were facing prosecution in Magistrates' Courts for VAT offences
- Advised clients from whom HMRC were claiming tax on behalf of other European Member States under the "MARD" (Mutual Assistance in the Recovery of Debts) procedure, and put forward arguments and evidence on their behalf
- Assisted a client in pursuing a successful claim for concessionary relief in respect of tax that had not been collected under the PAYE system because of errors by HMRC
High Court proceedings may also arise. This could take the form of judicial review, or a dispute between parties to a contract about an unexpected tax liability. Again, we have experience in these areas.
We have also helped with reports of undeclared funds under special disclosure schemes such as the Liechtenstein Disclosure Facility.
Examples of how we can help
- Advise on the merits of a case;
- Advise on the powers of HMRC;
- Make recommendations as to how to proceed;
- Collect evidence;
- Put forward arguments and evidence on behalf of the client;
- Prepare cases for hearing in a Tribunal or Court;
- Draw on our knowledge of the tax system as a whole when advising;
- Involve counsel, accountants and overseas tax specialists (with whom we have long-standing links) to assist as required.