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The standout tax disputes group at Herbert Smith Freehills LLP is led by Heather Gething, who is a judge in the First-tier Tax Tribunal, and is a veteran of tax investigations and litigation. She is supported by solicitor-advocate and newly promoted partner Nick Clayton who has developed a niche in advising clients in relation to civil and criminal measures aimed at penalising third parties who facilitate or enable tax evasion. Gething is currently advising Uber London on its defence of a High Court claim brought by Jolyon Maugham QC concerning the VAT liability of the client. Senior associate Michael Hunt specialises in cases involving the tax treatment of debt and derivatives; recently advising a corporate on a number of disputes arising from intra-group debt. Highlights included representing Bernard Charles Ecclestone in relation to ongoing proceedings in the Administrative and Commercial courts, challenging the legality of an HMRC decision to rescind a settlement agreement. The group is also acting for UBS Wealth as a defendant alongside other wealth-managers and independent financial advisers in multiple sets of negligence proceedings involving members of film partnerships who were not made aware of the tax risk of film partnership structures. 

Tax litigation boutique Joseph Hage Aaronson LLP is noted for its dominant position in the UK tax disputes market, enabled by its concentration of 'star individuals'. The group, which combines expertise from the Bar alongside solicitors and other experts including forensic accountants, handles complex domestic and cross-border tax disputes across a range of industry sectors for clients including Marks & Spencer,  Exxon and Sony. Founding partner Graham Aaronson QC leads the tax litigation tea, and specialises in commercial taxation - with a particular focuses on transfer pricing, oil and gas tax, life assurance office tax, structured finance, EU law and state aid. Vastly experienced Simon Whitehead is often instructed on contentious corporation tax matters, while Paul Farmer stands out for work involving European law and international tax. The group is currently representing British American Tobacco in the test case in the FII Group Litigation, which comprises 25 long-running claims by UK-headquartered multinationals challenging the UK's dividend taxation scheme and related issues. It is also acting for Prudential as the test claimant in the CFC and Dividend Group litigation, challenging the lawfulness of the UK's taxation of portfolio dividends and pension fund income. Other key names include Daniel Margolin QC, Michael Anderson, Ray McCann and 'solution-oriented' senior associate Helen McGhee who is singled out for her expertise in technical trust and offshore company matters. Former associate Philippe Freund joined Fieldfisher at partner-level in July 2018.

'Undoubtedly a leader in its field', Pinsent Masons LLP's tax litigation and investigations team members are noted for their experience and 'deep industry knowledge'. Areas in which the group has particular expertise include diverted profits tax issues, matters arising out of the Criminal Finances Act 2017 and judicial review challenges of HMRC's advance payment notices. Team leader Jason Collins (noted as 'practical' and 'calm under pressure') won a major victory for the BT Pension Scheme in the FIDs Group action before the European Court, successfully proving that HMRC had unlawfully withheld tax credits. With significant experience in tax disputes involving financial institutions, Stuart Walsh is representing RBS in two disputes arising from missing traders in its supply chains defaulting on VAT due to HMRC. Steven Porter is leading a series of Judicial Review challenges brought by various taxpayers against HMRC's decision to issue them with payment notices as a result of their prior involvement in tax avoidance schemes. Legal director Clara Boyd specialises in VAT disputes and is recommended for the 'razor-sharp intellect' she uses to 'effortlessly analyse complex legal concepts'.

Slaughter and May's team, which sits in both the tax and dispute resolution departments, has 'a pre-eminent reputation across the spectrum of its practice', which encompasses investigations, pre-litigation settlements and litigation before courts at all levels. The group is co-led by Richard Jeens and intellectual property-related tax expert Dominic Robertson. Jeens is currently providing technical tax and strategic advice to Hays in relation to a dispute with HMRC over the correct VAT treatment of introductions of temporary workers; in claims for the repayment of over £1bn. Sarah Lee is currently assisting Mercuria Energy Europe Trading with the defence of a £73m High Court claim brought against it and its co-defendant RBS in relation to a missing trader VAT fraud in the carbon emissions market. Other key practitioners include Steve Edge and Mike Lane.

Allen & Overy LLP's 'strong contentious tax offering' provides pre-litigation advice, handles negotiations and settlements with HMRC, and acts in administrative proceedings and tax litigation. Building on the firm's pedigree in the financial sector, the group is often counsel for tax matters involving banks and financial institutions. Indeed, 'technically very able' Charles Yorke is acting for Investec Bank in relation to an ongoing dispute with HMRC about whether the client's purchase of partnership interests and further contributions to the partnership constituted income, capital expenditure or whether costs were incurred for trading purposes. Vimal Tilakapala and Christopher Harrison co-head the team. Recent highlights for Harrison included successfully representing Lloyds Banking Group in dispute with HMRC regarding the correct VAT treatment of payments made towards redundancy costs. Lydia Challen is another name to note.

Ashurst has a broad contentious tax practice spanning enquiries, pre-litigation settlements and advocacy before tax tribunals. The group has particular tax grounding in the financial resources and infrastructure sectors and has developed expertise in relation to investigations and negotiations with the EU regarding state aid and harmful tax competition. Team head Nicholas Gardner is representing Carbon Capital in first-tier tribunal proceedings in relation to capital allowances claims by investors in its partnership; leading discussions with HMRC in relation to the settlement of its claims. Paul Miller is acting for Ocean Finance in relation to the Court of Appeal hearing being brought by HMRC in relation to allegations of VAT abuse. Alexander Cox advised the former Gala Coral Group in relation to the recovery of VAT from HMRC.

Baker McKenzie's multi-disciplinary team is noted for its depth of expertise, with specialist expertise covering the contentious aspects of corporate and indirect tax and transfer pricing. Drawing on the firm's global presence, it is particularly well placed to handle cross-border matters and disputes with multiple tax authorities, showcased by its involvement in major transfer pricing litigation involving Europe and the US, led on by Richard Fletcher and Kate Alexander. The group is jointly-led by Nigel Dolman and David Jamieson (who was made a partner in July 2018). Mark Delaney is singled out for work on global indirect tax projects and ability to coordinate with regulatory authorities. In a recent highlight, newly minted partner Jessica Eden acted for UK Power networks in a successful case before the First-Tier Tax Tribunal, defending claims for consortium relief made by a number of subsidiaries in the UKPN group.

The 'strong' team at Bryan Cave Leighton Paisner LLP  handles the spectrum of contentious tax issues, with a standout offering in relation to indirect tax matters. On the advisory front, the group is instructed on risk assessments in relation to the Criminal Finances Act 2017. In addition to leveraging the firm's real estate sector specialism, the team also has experience in customs and excise disputes, handling investigations and risk-advisory work. Promoted to partner in April 2018, 'hugely impressive' Kate Ison represented Hannover Leasing in its appeal to the First-tier Tribunal against HMRC's decision to apply stamp duty to a transaction that didn't happen. 'Outstanding in the field of VAT', Alan Sinyor is noted for his ability to 'impose order on complex disputes'. Global tax head Elizabeth Bradley is another key figure.

Fieldfisher is 'strong' for tax litigation, disputes and investigations, acting for a variety of corporate and individual clients. Drawing on underlying expertise within the firm, areas of particular expertise include tax matters relating to the film, leisure, life sciences and healthcare sectors. Another active area for the group is situations in which allegations of fraudulent or criminal conduct in a tax context have been made by HMRC. 'Good at keeping complex matters moving forward', Hartley Foster leads the team and currently represents Root 2 Tax in relation to a swathe of legal actions connected to advice given to hundreds of their clients. He is also representing Hoseasons in judicial review proceedings against HMRC in relation to the VAT treatment of credit card surcharges. 'Pragmatic and creative-thinker' George Gillham  (possessing 'strong technical ability and excellent judgment') is representing Invamed Group in a representative action for a group of retailers against HMRC, contesting liability to customs duty on mobility scooters imported from Taiwan and China. Philippe Freund joined at partner-level from Joseph Hage Aaronson LLP, where he was an associate.

The 'first-class' team at Hogan Lovells International LLP demonstrates 'superlative professionalism', handling the spectrum of tax disputes. 'Deeply technically able' Rupert Shiers leads the team and has particular experience in navigating HMRC discussions and tax litigation. Her is currently representing Ball UK Holdings at the appeal stage of its dispute with HMRC concerning historic corporation tax planning. Ruth Grant is acting for British American Tobacco in its tax tribunal appeal against HMRC's attempt to impose tax penalties on the client for alleged failure to prevent tobacco smuggling. Tom Mcfarlane leads the transfer pricing team and supply chain team, which includes Graham Poole, who is noted for his 'depth of knowledge' and 'invaluable practical application of the arms-length principle'. Lee Squires left for Grant Thornton UK LLP in June 2018, while Kevin Ashman retired in June 2017.

Quinn Emanuel Urquhart & Sullivan, LLP's team was greatly boosted by the arrival of the 'tenacious' Liesl Fichardt from Clifford Chance LLP in May 2017; the addition of Fichardt complements the team's existing expertise in high-value complex international tax litigation and arbitration, which is supported by Epaminontas Triantafilou and Anthony Sinclair. In one standout matter, the group is lead international counsel to Acacia Mining Group in its $200bn tax and arbitration dispute with the Tanzania Revenue Authority. In separate cases, it is representing various multinational mining, oil and gas companies in tax proceedings, and parallel arbitration proceedings, in a number of jurisdictions against the relevant government concerned pursuant to particular development agreements or tax and investment treaties.

The tax litigation and investigations team at RPC is led by former HMRC solicitor, Adam Craggs, who has significant experience in both direct and indirect tax dispute resolution, as well as tax enquiries and criminal tax investigations, EU law and business tax. Craggs is representing Coca-Cola European Partners (Great Britain) and 150 of its employees in relation to a dispute with HMRC concerning the tax treatment of vehicles used by employees during the course of their work; a case which is now at appeal in the Upper Tribunal. He is also acting for Newcastle United Football Club in HMRC's investigation into suspected non-payment of income tax, national insurance contributions and VAT in respect of agents' fees in player transfers. Other clients include Sports Direct, Greene King and Merlin Entertainments Group. Legal director Robert Waterson and senior associate Michelle Sloane are also recommended.

Simmons & Simmons has a dedicated contentious tax practice which spans civil and criminal tax disputes and other contentious issues, including liability and quantum advice, disputes with revenue authorities and regulatory investigations. 'A shrewd operator', Nick Skerrett, who leads the team, is noted as 'an excellent tactician and strategist'; and  successfully represented BPP Holdings in HMRC's appeal to the supreme court against a non-compliance bar, a precedent-setting decision. Skerret is ably supported by Darren Oswick, who is currently representing a large institutional asset manager in multiple tax disputes relating to loan relationships, transfer pricing, VAT and the corporate tax treatment of dividends under EU law. Martin Shah is another key practitioner and leads the firm's financial services tax practice. Senior associate Heather Rowlands is also recommended.

'A class act', Weil, Gotshal & Manges (London) LLP's practice includes the 'unflappable' Jamie Maples and Oliver Walker. The practice played a key role in The Littlewoods Group's landmark victories against HMRC before the High Court, Court of Appeal and the Supreme Court concerning compound interest due on VAT over-payments made by the client between 1973 and 2004. David Irvine is another key name for Weil.

Clifford Chance's strengths lie in its VAT and indirect tax litigation capabilities, led on by expert in the field, David Saleh. The group, benefiting from the firm's global presence, predominantly represents multinationals with complex tax requirements. Contentious real estate tax specialist Simon Corzberg is another key name.

Helen Buchanan leads the tax disputes team at Freshfields Bruckhaus Deringer LLP, with expertise in diverted profits tax, transfer pricing, valuation disputes, controlled foreign company issues and VAT and tax fraud matters. Buchanan is supported by Murray Clayson who focuses on disputes and investigations arising within the European Union. Helen Lethaby is another key contact.

Macfarlanes LLP is noted for its contentious indirect tax practice. The team, led by 'well-informed' Gideon Sanitt, includes former HMRC lawyer Nigel Doran, tax tribunal judge Ashley Greenbank, transfer pricing expert Batanayi Katongera, and VAT specialist Chris Mortimer, who joined from PricewaterhouseCoopers Legal LLP in February 2017. Highlights included defending Royal Mail against 300 claims on the basis that the client had been required to issue VAT invoices for services that were historically treated as exempt. The group is co-ordinating a case for a major commodities trader, which trades globally from a single central location, countering claims by an African country that is asserting the trader has a permanent establishment as a result of the client's activities in that country.

Mishcon de Reya LLP's 'commercially focused' tax litigation team of solicitor-advocates handles a range of complex disputes, including cases that require ADR. Department head Leslie Allen led Mercedes-Benz Financial Services UK's successful appeal against HMRC's decision to apply VAT to certain motor finance contracts. He is also representing Zipvit in a high-value case requesting the repayment of input tax incurred on supplies from Royal Mail. Managing associate Waqar Shah and consultant Dario Garcia are also recommended  for their extensive expertise in the area.

Norton Rose Fulbright's tax litigation group provides 'a high level of service'; with 'strong team members' available to support lead partners. It handle a wide range of tax-related investigations and contentious matters, including major cases before UK tribunals and courts. Dominic Stuttaford is acting for BMW in a case against other corporates regarding which entity within a VAT grouping is entitled to claim a refund, where there have been changes to the composition of the group over time. He is also representing HSBC in a restitution claim in the Franked Investment Income Group Litigation Order, involving complex and evolving areas of domestic and EU laws, and the availability of compound interest in tax remedies. Angela Savin has substantial experience at all stages of contentious matters, while commercial litigation and investigations specialist Ruth Cowley is recommended for her work on group litigation orders.

The 'great' team at Stewarts Law LLP is noted for providing 'speedy and practical commercial advice' and are particularly good at 'demystifying complicated legal issues'. Department head David Pickstone draws on his experience at a Big 4 accounting firm to advise on a variety of tax disputes. Complimenting Pickstone's area expertise,  the team welcomed Victor Cramer from KPMG United Kingdom in January 2018. Demonstrating the group's strength, it is currently representing multiple high-net-worth individuals in an action against Ingenious Media, Coutts, UBS and other independent financial advisors regarding faulty advice about the tax implications of film partnerships. It is also representing FCC Environment UK and FCC Recycling as defendant and counterclaimant in $40m cross-claims against HMRC for the recovery of landfill tax and VAT. Senior associate Lee Ellis is also recommended.

Eversheds Sutherland (International) LLP's contentious tax team draws on practice head Giles Salmond's experience in VAT matters to handle a wide range of indirect tax issues. Past work has included successfully negotiating with HMRC and Barclays Bank on behalf of the Government Property Unit of Cabinet Office  in relation to a complex VAT issues arising out of a new government hub. David Jervis is another recommended practitioner.

The team at Kuit Steinart Levy LLP 'compares favourably with London-based specialists', especially in relation to HMRC investigations. The group has developed a miche in the area of disclosure of funds held in offshore jurisdictions and continues to advise clients on UK-focused HMRC investigations and international disclosures, including defending investigations and challengin them when they are believed to be unfounded. With a 'very good background in tax litigation' executive partner Robert Levy is 'a strong advocate who handles clients and HMRC calmly and effectively'.

PwC Legal LLP leverages its existing Big 4 accounting expertise in a wide range direct and indirect tax disputes at every level of the UK court system and through ADR and mediation. Mark Whitehouse (a former HMRC solicitor) and David Anderson are the key contacts. The group won a significant victory for Jazztel, BSkyB and others in claims for restitution against HMRC arising out of a change to SDRT and stamp duty, recovering significant sums of tax.

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