Firms To Watch: Tax litigation and investigations

Kirkland & Ellis International LLP is strengthening its contentious tax practice with the addition of Alexander Cox from Ashurst and Kunal Nathwani from Eversheds Sutherland (International) LLP.
Boutique firm Corker Binning has extensive expertise in the fields of financial crime and financial services, regularly advising both individuals and entities on HMRC investigations.

Firms in the Spotlight Tax litigation and investigations

Ronald Fletcher Baker LLP

Ronald Fletcher Baker has an established track record of success in even the most complex cases. Litigation and Dispute Resolution has been a focus of the firm since its inception in 1948, and our highly experienced team is widely recognised for its skill in this area. The firm deals with a broad range of commercial …

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Tax litigation and investigations in London

Herbert Smith Freehills LLP

Herbert Smith Freehills LLP is one of the leading contentious tax teams in London undertaking a broad range of work including direct business tax, personal tax, employment tax and indirect tax disputes. The practice are increasingly focused on tax fraud matters with HMRC pursuing more criminal investigations and prosecutions. Nick Clayton leads the team and handles the full spectrum of tax disputes with a focus on tax fraud and investigations. Michael Hunt works closely with the employment team on contentious matters relating to worker status and internationally mobile employees. Associate Dawen Gao is a highly regarded practitioner.

Practice head(s):

Nick Clayton

Other key lawyers:

Michael Hunt; Dawen Gao

Testimonials

‘The team is extremely knowledgeable and approachable. They are able to translate ‘legalese’ into plain English and we have found them a pleasure to work with.’

‘Nick Clayton and Steven Wenham have been excellent in supporting our business. Quick to respond, very engaging and have very detailed knowledge and innovative solutions.’

 

Key clients

Uber

UBS

PacifiCorp

Awilco Drilling

Orsted

Work highlights

    Joseph Hage Aaronson LLP

    Joseph Hage Aaronson LLP is a boutique dispute resolution firm which specialises in tax litigation, commercial litigation and international arbitration. The team acts in a number of high value recovery claims by major multinationals in complex domestic and cross-border tax disputes. The firm also have a growing expertise in cryptocurrencies and non-fungible tokens. Graham Aaronson KC founded the firm in 2013 and co-heads the practice with Michael Anderson who is experienced in running major tax disputes in non-UK jurisdictions. Simon Whitehead is well-versed in corporation tax matters with support from Shofiq Miah while Paul Farmer is an expert in European tax law.

    Practice head(s):

    Graham Aaronson KC; Michael Anderson

    Other key lawyers:

    Simon Whitehead; Paul Farmer; Shofiq Miah

    Testimonials

    ‘The team at JHA all seem to work together and work moves around the team seamlessly. They are all great at explaining complex legal matters in terms that can be understood by non-legal people.’

    ‘The stand out partner for me is Simon Whitehead who is always engaging on calls and provides sage advice and opinions.’

    ‘I have engaged with the JHA team for over 10 years. They have been assisting my company with a tax litigation. JHA are the experts in this matter. I have always found the team has been able to explain very complicated matters to me in a simple and understandable manner, and to fully engage with me as the case has developed over the years.’

    ‘I have mainly worked with Simon Whitehead of JHA. He is very helpful in explaining the development of the litigation, including potential impacts on the eventual valuation of the case, for my company. Simon is very commercially aware, fully understanding the costs / benefits consequences of the case for my company and is fully aware of the cost constraints affecting my company. I do have regular calls with Simon to discuss the implications of the litigation to my company – at the moment there are separate, but connected, actions affecting the case, and of course, HMRC often raise complicated arguments to the claims of the taxpayers, which Simon is able to fully explain and assess potential implications for my company.’

    ‘Pioneers of the tax GLO. Market leading team. Hugely impressive tacticians and technically excellent.’

    ‘Practical, responsive provide solutions and solve problems’

    ‘Shofiqur Miah has always been reliable, responsive and extremely thorough.’

    ‘Approachable, no frills solid advice!’

    Key clients

    British American Tobacco

    Marks & Spencer

    Prudential

    Intercontinental Hotels Group

    Richemont

    Akzo Nobel

    GKN

    Fidelity

    JJ Management LLP

    Shield Contract Services UK Ltd

    Work highlights

    • Advised 25 UK headquartered multinationals in their challenge to the UK’s dividend taxation scheme.
    • Advised Fidelity in relation to ongoing litigation in the Danish courts.
    • Pursued Closure Notice Applications in the First-tier tribunal on behalf of a group of approximately 180 taxpayers.

    Slaughter and May

    The tax disputes team at Slaughter and May are frequently involved in high-profile tribunal cases and advise on mandates such as transfer pricing, state aid and tax residence. The firm undertakes both transactional and contentious matters with the ability to provide cutting-edge advice on evidence gathering, privilege and dealing with witnesses. Richard Jeens  co-heads the practice with Dominic Robertson  who regularly handles EU tax state aid investigations. Steve Edge is an accomplished contentious tax practitioner while Ewan Brown  co-heads the global investigations group.

    Practice head(s):

    Richard Jeens; Dominic Robertson

    Other key lawyers:

    Ewan Brown; Steve Edge

    Testimonials

    ‘Slaughter and May has a legendary tax team with an excellent reputation spanning many decades.’

    ‘This is an exceptional team with outstanding legal ability and analysis and a huge range of experience of all areas of tax and industry.’

    ‘Unrivalled technical expertise, knowledge and confidence in backing own position.’

    ‘Always on and commitment to deliver results on time.’

    ‘A deep knowledge of tax and client care that is second to none: they leave me feeling I am in safe hands and even the most intractable problem can be resolved.’

    ‘Steve Edge is a living legend in the UK tax world. He learned his craft from people who were practicing when corporation tax and capital gains tax were introduced in 1965. His breadth of experience is unparalleled. But he is no mere elder statesman, wheeled out on grand occasions to utter a few platitudes and reel off tired anecdotes from days gone by: he is as sharp as ever and more able to focus on work and clients that he finds interesting and where he thinks he can add value. He is a great ally to have.’

    ‘The Slaughter and May team were absolute experts in tax litigation, but they were unique in how they brought a very focused and commercial approach as well as their expertise to this litigation. These capabilities with their collaborative and creative approach set them apart from any other advisers and meant that collaboration with the Slaughter and May team was seamless and delivered an exceptional services at all times.’

    ‘James Stacey and his team William Burrows and Ross O’Mahony were highly skilled professionals, very commercial and focused and quick to get to the nub of matters. They were fully committed to solving the case and any problem was addressed fully and comprehensively.’

    Key clients

    BlueCrest

    GlaxoSmithKline

    Mercuria Energy Europe Trading

    Vodafone

    Vitol

    Work highlights

    • Advised the Vitol group in relation to anongoing transfer pricing and diverted profits tax (DPT) dispute with HMRC.
    • Advised BlueCrest on several matters relating to challenges to the UK tax treatment of its management incentivisation arrangements.
    • Advised Vodafone and GSK on the European Commission’s State aid investigation into the group financing exemption from the UK’s CFC rules.

    Allen & Overy LLP

    Allen & Overy LLP‘s contentious tax practice includes pre-litigation advice, negotiations and settlements with HMRC, commercial litigation proceedings and tribunal hearings. The firm has a varied client base with companies across the financial, consumer, retail, energy and transport sectors. Co-head Charles Yorke has experience of managing large-scale investigations by HMRC’s fraud investigation service. Vimal Tilakapala‘s practice involves finance-related tax including structured finance, regulatory capital and securitisation. Eve Giles specialises in financial crime investigations while Lydia Challen advises on supply chain finance and repackagings.

    Practice head(s):

    Charles Yorke

    Other key lawyers:

    Vimal Tilakapala; Eve Giles; Lydia Challen

    Testimonials

    ‘Very high quality of people.’

    ‘Bright and hard working. They want to be involved in the detail and all the potential options.’

    ‘Charles Yorke in particular is extremely bright and thorough.’

    Work highlights

    • Advised Investec Bank plc before the Court of Appeal.
    • Advised various financial institutions in relation to the fall-out from the German cum-ex investigations.

    Ashurst

    Ashurst has an active tax disputes practice which is considered a market leader in the context of VAT litigation, indirect tax, employment taxes, and EU State Aid. The firm primarily undertakes work for financial institutions, funds, premium corporates and infrastructure companies.  Nicholas Gardner heads the team and has extensive expertise in relation to the resolution of disputes with HMRC and contentious tax matters generally. Paul Miller focuses on the financial services industry while Sara Mardell advises clients in relation to VAT and national insurance issues.

    Practice head(s):

    Nicholas Gardner

    Other key lawyers:

    Sara Mardell; Paul Miller

    Testimonials

    ‘Continuity in the team over several years. The practice is solution oriented and able to set them into our case/issues to be solved. Likeable people with good collaboration.’

    ‘Expressed ownership and responsibility for our case. Senior associate major contact with outstanding performance.’

    ‘Very commercial with great technical knowledge. Knows when to use counsel and how to delegate to make best use of all resources and talents. Hard working. Sound. They will stand by their advice as well. Won’t plug aggressive planning that doesn’t work.’

    ‘Great for VAT and for SDLT.’

    ‘Paul Miller is very approachable and hard working. Simon Swann has great judgment.’

    ‘A world class tax litigation and investigations practice. Genuine leaders in their field, with unparalleled experience conducting litigation at all levels and across all practice areas. It is no coincidence that they achieve a very high level of success for their clients.’

    ‘Nick Gardner combines superb technical knowledge with an instinct for those points which will go down well in Court. He is a true professional, among a small handful of practitioners I would recommend without hesitation. Sara Mardell is an absolute joy to work with, inspiring both clients and colleagues. She has a natural flair for litigation, able to spot and then develop case-winning points. She also has a phenomenal work ethic. She is a star that will continue to rise.’

    Key clients

    Imperial Brands PLC

    Hastings Insurance Services Limited

    Work highlights

    • Advised Mark Shaw as nominated partner of the TAL on his successful appeal to the Upper Tribunal from a decision made by HMRC to disallow certain claims for industrial buildings allowances.
    • Advised Imperial Brands PLC on its appeal to challenge the EU’s decision that the UK CFC regime was unlawful state aid and that the UK should recover the benefit of the state aid from those groups.

    Baker McKenzie

    Baker McKenzie provides domestic and international tax disputes advice to multi-nationals with expertise across several sectors including financial institutions, healthcare, TMT and FMCG. The team is experienced in advising clients on European State Aid investigations, corporation tax disputes and transfer pricing matters. David Jamieson heads up the VAT and indirect tax disputes practice while Jessica Eden leads the corporate tax cases. Economist Nigel Dolman specialises in defending global transfer pricing and valuations across different industries. Patrick O’Gara  has expertise in the pharma and life sciences sectors.

    Practice head(s):

    David Jamieson; Jessica Eden; Nigel Dolman

    Other key lawyers:

    Patrick O’Gara

    Testimonials

    ‘A good team with sound tax technical knowledge and good strategic judgment.’

    ‘Baker McKenzie’s tax practice is unique because it is so closely integrated with the firm’s customs practice. As a result, the firm is a one-stop-shop for multinational companies seeking to base the customs values of their products on internal transfer prices between affiliates, which can be necessary but also trigger enhanced regulator scrutiny. Baker McKenzie lawyers are adept at working within a company’s existing transfer pricing/tax setup to find a customs valuation approach that will pass regulator scrutiny.’

    ‘This practice has people knowledgeable about UK tax law and procedures who were able to guide us through the new PDCF process and obtain a favorable outcome. They also were able to coordinate with offices in other countries to ensure favorable resolution.’

    ‘Patrick O’Gara led the PDCF filing project, helping to report our information in the way that HMRC expected to see it. Jukka Karjalainen provided excellent guidance and write-up in the transfer pricing area, including proving that other transfer pricing areas did not need adjustments.’

    Key clients

    Accenture

    Baker Hughes

    Core Media

    Electronic Arts

    European Tyre Enterprise Limited

    Hutchison 3G Limited

    Marriott

    MDU (Medical Defence Union Limited)

    UK Power Networks

    Work highlights

    • Advised the Kwik-Fit Group on a long running dispute with HMRC concerning whether a restructuring of the group’s inter-company balances gives rise to an unallowable purpose for the existing receivables.
    • Acted for the Medical Defence Union in its successful appeal to the Upper Tribunal against the decision of the First-tier Tribunal.

    Bird & Bird LLP

    The contentious tax team at Bird & Bird LLP assists clients throughout the full cycle of a dispute from providing pre-emptive compliance advice to making disclosures to relevant authorities and bringing civil litigation. The team deals with tax authorities in relation to all types of issues including transfer pricing and diverted profit matters. Andy Brown heads the practice and specialises in cross-border disputes while Chris Young is well-versed in areas such as money laundering.

    Practice head(s):

    Andy Brown

    Other key lawyers:

    Chris Young

    Testimonials

    ‘This team is unique because it has a wealth of experience in this field and can draw upon a diverse experience of inter connected and related practice areas. I have worked with the team on matters that have included internal investigations, civil/criminal cross over cases, as well as matters that have progressed to criminal prosecutions by HMRC. The team therefore sets itself apart from its competitors.’

    ‘Andy Brown heads the team and is impressive. He has vast experience and is particularly well organised and is able to break down complex issues into their most important parts. In addition, he is adept at providing practical advice to the firm’s clients. The associates in the team are high level, notably Chris Young.’

    ‘They are sophisticated and practical at the same time which is relatively rare in their field. Cross border tax disputes and remediation in the context of M&A is normally the preserve of the Big 4. This team however is very adept at creating a process and structure which will help a deal happen when tax might otherwise have caused it to abort.’

    ‘Andy Brown and Chris Young are a good double act. However Andy Brown is stand out. I would happily bring him in where there is a tricky tax problem which may need remediation in multiple jurisdictions to save a deal. Good value, practical, but technical enough for the nerds in the room.’

    ‘Strong team of hard-working solicitors with good technical knowledge and fully focused on the needs of the client.’

    ‘Chris Young is hard-working, practical and good understanding of principles. Excellent on litigation, advice and transactional work.’

    ‘Very experienced team under the leadership of well-respected Partner Andy Brown who are well able to handle all types of tax dispute resolution work with tax authorities. Particularly impressive in respect of being able to bring other specialist to the table (VAT, Transfer Pricing, IT specialists, Forensic Accountants etc.) and manage disputes across multiple jurisdictions with a strong network of local experts both within and outside Bird & Bird. Andy is able to “open the door” to the impressive cross firm cross geographic capabilities of Bird & Bird, but is not afraid to pull in subject matter experts outside the firm when the case requires external input.’

    ‘Andy Brown is my go-to Partner for tax dispute questions and complex disclosure projects. He combines deep technical skills with strong project management capabilities and stays cool under pressure. I have personally seen him navigate and resolve complex and at times very difficult meetings where emotions were high, and participants had very conflicting objectives. He is almost always able to propose a resolution that all parties can eventually agree, however intransigent initial positions appear or difficult the case may be.’

    Key clients

    B&M Retail

    Sporting Wholesale Limited

    W F & L Limited

    Push Energy

    CVR Global Offshore Limited

    Work highlights

    • Advised a multinational global leader in real time advertising technology and programmatic media trading on resolving its global tax risks with an estimated value of $102m.
    • Advised the senior management of a manufacturing business through the contractual disclosure facility for deliberate overclaiming monies under the coronavirus job retention scheme.
    • Advised a UK subsidiary of a South Korean business in relation to recovery of over £20m of input VAT and the zero-rating of luxury fashion goods to South Korea.

    Bryan Cave Leighton Paisner LLP

    The contentious tax practice at Bryan Cave Leighton Paisner LLP, overseen by global head Elizabeth Bradley, covers the full spectrum of matters with increased focus on corporation tax and employment tax disputes as well as tax fraud issues. Kate Ison specialises in contentious tax with expertise in marketing and technology sectors. Alan Sinyor is a VAT practitioner and deals with high value and cross border VAT disputes with HMRC.

    Practice head(s):

    Elizabeth Bradley

    Other key lawyers:

    Kate Ison; Alan Sinyor

    Testimonials

    ‘Very efficient and responsive. Practical and down to earth, whilst being very reassuring to the clients.’

    ‘Kate Ison is terrific – clever, sensible, hard working and very efficient. She has absolutely no edge or ego.’

    ‘There is a very good synergy between the commercial litigators and the VAT team. Each play to their strengths which significantly improves their offering to the client.’

    ‘Alan Synor and Kate Ison are standout. Both technically very sound and work well together as a team, Kate focusing on litigation strategy and Alan on VAT technical issues.’

    Work highlights

      Clifford Chance LLP

      Clifford Chance LLP‘s contentious tax practice has expertise in complex international and cross border investigations and disputes involving VAT. Recent highlights include advising in relation to a dispute around the tax treatment of foreign tax credits. Co-head David Saleh has particular expertise in real estate-related taxes while other co-head David Harkness specialises in corporate and finance tax. Associate Nicola Hemsley focuses on tax disputes with clients such as financial investors and institutions.

      Practice head(s):

      David Saleh; David Harkness

      Other key lawyers:

      Nicola Hemsley

      Key clients

      Major banks

      Investment funds

      Corporate entities

      Work highlights

        Fieldfisher

        The contentious tax team at Fieldfisher has expertise in a variety of tax disputes topics including disclosures, resolution of HMRC enquiries, criminal enquiries and professional negligence claims. There is also a substantial international element to the work being done evidenced by frequent dealings with German tax authorities. George Gillham co-heads the practice with Derek Hill who had expertise in the media and film sectors. Barrister and partner Philippe Freund is involved in cases ranging from the Tax Tribunals to the Supreme Court. Matthew Sharp specialises in contentious tax matters.

        Practice head(s):

        Derek Hill; George Gillham

        Other key lawyers:

        Philippe Freund; Matthew Sharp

        Testimonials

        ‘George Gillham is one of the best tax litigators around, highly experienced with excellent background in tax work.’

        ‘Excellent technical knowledge as well as practical experience in dealing with HMRC.’

        ‘Matthew Sharp is both technically excellent and has strong client service skills.’

        ‘A team with breadth and strength in depth. Significant expertise in both high court litigation and before the tax tribunal combined with strong technical tax knowledge.’

        ‘Matthew Sharp is a real gem – an eye for detail without losing sight of the broader commercial strategy.’

        ‘Particular expertise in property taxes. Boutique.’

        Key clients

        Invamed Group Ltd

        Sunrise Medical Ltd, Invacare Ltd

        Roma Medical Ltd

        Days Healthcare Lt

        Drive deVilbiss Healthcare Limited

        Sunrise Medical Ltd

        TGA Mobility Limited

        Electric Mobility Euro Limited

        Aramark Limited

        Sunrise Medical BV & Sunrise Medical Logistics, B.V.

        Work highlights

        • Advised Sunrise Medical Ltd, Electric Mobility Euro Ltd, TGA Mobility Ltd, Drive DeVilbiss Ltd on a £6,000,000 Group Litigation before the FTT.

        KPMG Law in the United Kingdom

        The tax disputes and investigations team at KPMG Law in the United Kingdom acts on all types of domestic and cross-border matters including corporation tax, customs and excise duties and income tax for high net-worth individuals. Recent highlights include representing HSBC in a novel dispute about non-incorporated entities which has far-reaching consequences for UK VAT law. Angela Savin has a range of direct tax dispute resolution expertise and co-heads the team with Matthew Fleming who leads the indirect tax disputes practice. Amanda Brown KC is a rated barrister who represents clients in a range of disputes.

        Practice head(s):

        Angela Savin; Matthew Fleming

        Other key lawyers:

        Amanda Brown KC

        Testimonials

        ‘The team is highly efficient, and very commercial in its attitude. Very high degree of expertise in the field.’

        ‘A large tax focused team with a great deal of depth and knowledge.’

        ‘KPMG’s tax investigations team is very experienced and are astute in dealing with HMRC investigations.’

        ‘It can draw on its extensive accountancy and consulting practice.’

        ‘KPMG Law has real depth of talent, from the top partner level down to the trainees. Everyone seems to work very well as a team, collaborating and cooperating. They have particular strength in large tax litigation matters, and can manage cases all the way through a dispute.’

        ‘Matt Fleming is excellent. His VAT knowledge is second to none. He inspires confidence.’

        ‘Amanda Brown KC is a class act. The grand dame of indirect tax.’

        ‘I like working with Amanda Brown. She is extremely knowledgeable, as would be expected of a KC, however is pragmatic and able to think commercially. She is able to explain complex legal jargon in a non-patronising, inclusive way, and clear with her analysis of a situation.’

        Key clients

        Cape Industrial Services Limited

        Devon Waste Management

        DHL Air Ltd

        English National Ballet

        Euromoney plc

        Gap Group Limited

        Gloucestershire Hospitals NHS Foundation Trust

        John Hargreaves

        HSBC Bank plc

        Intercontinental Hotels

        Jupiter Asset Management plc

        Key Group Limited

        Kopparberg

        Lloyds Banking Group

        Poundland Limited

        Robert Wiseman and Sons Limited

        Silver Seas Property Holdings Sarl

        Thyssenkrupp Materials (UK) Limited

        United Grand Lodge of England

        Volkswagen Financial Services (UK) Limited

        William Archer

        William Hill plc

        Work highlights

        • Represented HSBC in a novel and untested VAT law dispute with HMRC.
        • Represented John Hargreaves in challenging the competency and validity of a discovery assessment which was made by HMRC for income and capital gains tax.

        Macfarlanes LLP

        Macfarlanes LLP advises on the full spectrum of tax matters from HMRC enquiries to audits, investigations and litigation. The team handles both direct and indirect tax disputes with many going before the tax tribunals and civil courts. Other areas of expertise include transfer pricing and offshore trusts matters. Gideon Sanitt heads the team with experience in both transactional and contentious work with support from Sebastian Prichard Jones. Ben Webster acts on a wide range of tax disputes including traditional HMRC matters and judicial review cases.

        Practice head(s):

        Gideon Sanitt

        Other key lawyers:

        Sebastian Prichard Jones; Ben Webster

        Testimonials

        ‘The quality of solicitors working in the team are able to attract top quality private clients. The litigation and investigations team fits very well with the private client teams to resolve disputes with HMRC.’

        ‘Very hard working. Substantial experience in litigation and investigations. Very high quality recent hires from HMRC.’

        ‘Exceptionally hard working. Technically brilliant. Savvy litigators.’

        ‘The superb Gideon Sanitt.’

        ‘Macfarlanes has a specialist team which conducts it’s tax litigation and investigations practice. As with everything that Macfarlanes does, the standard applied is excellent, maintained and enhanced by knowledge and experience.’

        ‘The tax litigation and investigations team at Macfarlanes is led by Gideon Sanitt, a practitoner of huge experience and the ability to explain the issues which arise in litigation to lay clients in terms which they can understand. Gideon is supported by a large team with large resources. All the members of the team are exceptionally able and approachable and available.’

        ‘The team are very commercially minded and able to apply complex tax law to the real world and explain it to clients in a way they understand. They are technically very strong and understand the law but not at the expense of being personable and clear in their advice. They are very responsive and pro active and offer clear advice and explanations of risks and legal process. They do no shy away from giving advice that may not be what the client was expecting/hoping to hear. They are experts in their field and work very well with barristers and their clients.’

        ‘Unusually compared to many other firms, the members of the team are on the one hand very intelligent and therefore able to deal with technical issues, but also very commercial.’

        Pinsent Masons LLP

        Pinsent Masons LLP‘s tax disputes and investigations team advise several large companies on IR35 legislation and international tax issues such as diverted profits tax. The practice do a lot of work in the energy sector on matters such as the Construction Industry Scheme (CIS). The firm are also strong in handling employment and business crime tax-related issues. Steven Porter heads the practice and has a wealth of experience in contentious and non-contentious tax matters. Andrew Sackey is experienced in domestic and international investigations, while Jake Landman specialises in tax disputes and advising large corporates.

        Practice head(s):

        Steven Porter

        Other key lawyers:

        Andrew Sackey; Jake Landman

        Testimonials

        ‘The ability to have specialist legal expertise in-house was a key attraction for the firm, as was their knowledge and expertise of the industry sector.’

        ‘Strong Case management. Very responsive to questions. Very conscious of costs management.’

        ‘The team take time to understand how our business operates and its priorities. There is a great breadth of knowledge and the capability to adapt the way they work to suit business need. They work hard to become an extension of our business on the matters where we instruct them.’

        ‘Jake Landman is excellent. He is a superb lawyer but also adept at engaging with people at all levels within the business. He takes time to understand what the business wants to achieve and strives to deliver it. He is very comfortable with complex detail and is always well prepared to delve into the nitty gritty. Jake is also very responsive.’

        ‘Excellent, hard working, good with clients.’

        ‘Steven Porter is very hard working and always one step ahead of the opposition.’

        ‘Leaders in the field of tax litigation.’

        Key clients

        Raymond Tooth

        Natwest Group

        Cantor Fitzgerald

        The Gala Film Partners LLP

        Centrica

        Darty Limited,

        E-zec Medical Transport Services Ltd

        Work highlights

        • Acted for Raymond Tooth in proceedings before the Tax Chamber of the First-tier Tribunal, Upper Tribunal and Court of Appeal.
        • Advising on the MOD’s group action who are challenging a discriminatory UK WHT suffered on certain income derived from lending non-UK shares.
        • Acted for NatWest Group in an £86 million VAT dispute with the potential for a further penalty up to 100% of the VAT.

        PwC LLP

        PwC LLP has a large contentious tax team consisting of solicitors, barristers, accredited mediators, CTAs and accountants. The team provides expertise across a number of sectors such as financial services, retail, gaming, manufacturing, telecommunications, leisure and education. The team is frequently involved in tax litigation, tax investigations, transfer pricing and ADR work covering multiple jurisdictions. Stephen Morse leads the practice with experience in direct tax, VAT, transfer pricing and personal taxes. Mark Whitehouse has expertise in tax planning challenges, HRCP cases, corporate tax appeals and judicial reviews. David Anderson  is well-versed in contentious and non-contentious matters.

        Practice head(s):

        Stephen Morse

        Other key lawyers:

        David Anderson; Mark Whitehouse

        Key clients

        General Electric

        IHS Markit

        Worldpay, Inc / FIS Global

        Telent Technology Services

        Dollar Financial UK Limited

        Brett Aggregates Limited

        Hippodrome Casino Limited

        General Electric Pension Funds

        Jazztel plc

        Work highlights

          Quinn Emanuel Urquhart & Sullivan, LLP

          Quinn Emanuel Urquhart & Sullivan, LLP has expertise in sensitive taxation and financing-related matters. The practice is experienced in regulatory and high-net worth tax investigations, arbitration disputes and multi-jurisdictional challenges faced by UK-based or UK-connected nationals. Practice head Liesl Fichardt specialises in complex tax, finance and debt-related investigations with HMRC. Epaminontas Triantafilou frequently represents clients in international arbitrations while associate Emily Au assists with forensic tax investigations.

          Practice head(s):

          Liesl Fichardt

          Other key lawyers:

          Epaminontas Triantafilou; Emily Au

          Testimonials

          ‘The firm is one of the leaders in international and cross-border tax disputes.’

          ‘Liesl Fichardt is a phenomenal tax disputes lawyer with a fantastic knowledge and experience of cross-border taxation issues affecting corporations and corporate groups. She has a stellar reputation and client list to match. A brilliant team leader, an astute negotiator, incredibly accessible and user-friendly and always focused on securing the right commercial result for best value.’

          ‘This team bring, to UK tax litigation, the guts and determination which are the hallmarks of US litigators and marries it with the huge experience and management skill of Liesl Fichardt who has great knowledge of managing group litigation. The team also has the research skills and the depth of knowledge properly to analyse a problem and to bring it successfully to trial.’

          ‘Liesl Fichardt leads the team and is assisted by an able group which includes the highly able Matthew Tse. The members of the group are easy to work with and approachable.’

          ‘Liesl Fichardt is the tax litigator’s litigator. Her consumate skills and energy drive everything she does in resolving the most complex tax disputes.’

          Key clients

          Lockton Group Companies

          Premier Team Holdings Ltd

          The Trustco Group

          Global Media / Bauer Media

          Radiocentre Limited

          Barrick Gold Corporation Group and international subsidiaries

          Anglo Gold Ashanti

          Work highlights

          • Advised Saracens Rugby club in complex tax and regulatory disputes.
          • Provided ongoing advice to Canadian – UK Barrick Gold in their billion dollar tax disputes against the Tanzanian Government.
          • Advised Trustco Ltd in a complex appeal currently pending before the Court of Appeal.

          RPC

          The tax litigation team at RPC has extensive experience in all aspects of HMRC investigations with a particularly strong sports and entertainer client base. The team is instructed in some of the largest UK and European Court of Justice tax cases in addition to representing several taxpayer companies and individuals in public law group actions against HMRC. Adam Craggs heads the practice and has particular expertise in dealing with enquiries and complex tax litigation. Robert Waterson  focuses on multijurisdictional disputes while Michelle Sloane  advises both corporates and high-net worth individuals. Associate Harry Smith has experience across a range of direct and indirect taxes.

          Practice head(s):

          Adam Craggs

          Other key lawyers:

          Robert Waterson; Michelle Sloane; Harry Smith

          Testimonials

          ‘Expert knowledge on technical tax issues, dealt with efficiently.’

          ‘Good communication skills.’

          Key clients

          TSB Plc

          Frasers Group PlC

          Universal Cycles

          Metropolitan International Schools Ltd

          Newcastle United Football Club

          Steven Hoey

          Clipperton & Lloyd

          AML Tax (UK) Ltd

          Jones Bros Ruthin (Civil Engineering) Co Ltd

          Britannia Hotels Limited

          Work highlights

          • Advised TSB in relation to a complex VAT dispute concerning the correct treatment of services provided to it under a transitional services agreement arising out of its split with Lloyds.

          Simmons & Simmons

          Beyond the mainstream tax tribunal litigation, Simmons & Simmons specialises in commercial tax litigation, e-discovery, regulatory investigations, fraud work and professional negligence. The firm has sector expertise in the asset management, TMT, healthcare and life sciences industries. Nick Skerrett leads the team and is experienced in litigating high-value tax cases. Monique Van Herksen specialises in transfer pricing controversy and dispute resolution. Heather Rowlands advises corporate clients on VAT disputes.

          Practice head(s):

          Nick Skerrett

          Other key lawyers:

          Monique Van Herksen; Heather Rowlands

          Key clients

          Augean plc

          Veolia

          Christopher Rokos

          Fidelity

          Halfords

          Work highlights

          • Acted for Chris Rokos in High Court professional negligence proceedings against Deloitte LLP and McDermott Will & Emery LLP.
          • Advised two of the four parties to the Devon Waste Management litigation on appeals that are collectively worth around £6 billion to the landfill sector.
          • Acting for Augean plc on appeals against landfill tax assessments imposed by HMRC, a case of general significance to the landfill sector.

          DLA Piper

          DLA Piper helps clients to manage complex civil and criminal fraud investigations while also providing contentious tax expertise. The practice has been significantly strengthened in recent months by a series of hires from Pinsent Masons LLP, including international tax controversy head Jason Collins and senior associate Lauren Redhead in 2021, followed by legal director Clara Boyd and Stuart Walsh in 2022, further boosting the team’s expertise in relation to contentious VAT and excise duty matters. Richard Woolich covers indirect tax issues such as excise duty, carbon pricing and landfill tax in addition to transfer pricing matters.

          Practice head(s):

          Jason Collins

          Other key lawyers:

          Lauren Redhead; Richard Woolich; Clara Boyd; Stuart Walsh

          Testimonials

          ‘Very experienced in relation to commercial tax issues and litigating against HMRC.’

          ‘Jason Collins is fantastic. The team has huge all round tax knowledge.’

          ‘Jason Collins is a really top tax professional who has bags of knowledge and experience.’

          ‘Jason Collins brings huge tax dispute resolution experience to bear in dealing with the most challenging problems both domestic and international. Clients appreciate his calm and sound judgement.’

          Key clients

          Mid Ulster District Council

          JVM Equipment Limited

          Westland Horticulture Limited

          Work highlights

          • Acted for Mid Ulster District Council in its successful appeal for refunds of wrongly paid VAT on leisure and recreational services before the First-tier Tribunal.
          • Represented JVM Equipment Limited in connection with a Transfer Pricing and Diverted Profits Tax dispute.
          • Acted for Westland Horticulture in a Tribunal appeal and Judicial Review proceedings regarding the VAT treatment of grass seed and HMRC’s published guidance.

          Ernst & Young LLP

          Ernst & Young LLP acts for clients in the largest and most complex tax disputes in litigation from the First-tier Tribunal to the Supreme Court. The firm’s client base ranges from ultra-high net worth individuals to corporates with a particular strong presence in the oil and gas sectors. Boaz Goren leads the direct tax litigation practice with a wealth of experience practicing as a tax and commercial litigator. Other head Mitchell Moss leads the indirect tax practice with dispute resolution experience in VAT. Julian Balson assists clients in tax-related enquiries, investigatons and proceedings.

          Practice head(s):

          Boaz Goren; Mitchell Moss

          Other key lawyers:

          Julian Balson

          Key clients

          Biffa Waste Services Limited

          Dolphin Drilling Limited

          Work highlights

          • Advised and represented Biffa Waste Services Limited at the FTT, UT and Court of Appeal on a dispute in relation to the landfill tax treatment of a certain material.
          • Advised and represented Dolphin Drilling Limited at the FTT in relation to its dispute with HMRC regarding the application of Part 8ZA of Corporation Tax Act 2010 (CTA 2010) to a particular offshore oil drilling support asset.

          Eversheds Sutherland (International) LLP

          Eversheds Sutherland (International) LLP provides practical contentious tax advice on issues such as VAT, customs duties, loan relationships, SDRT and tax investigations. In addition the team has expertise in acting for clients in judicial reviews and advising on precedent-setting cases of tax discrimination. David Jervis co-heads the team with Giles Salmond  who specialises in indirect tax with a focus on contentious VAT. Edward Griffiths  advises clients on disputes with HMRC from pre-action through to trial.

          Practice head(s):

          Giles Salmond; David Jervis

          Other key lawyers:

          Edward Griffiths

          Testimonials

          ‘Very approachable.’

          ‘Edward Griffth is very approachable and gives timely updates.’

          ‘An engaging and client focused team offering practical yet cutting edge strategic advice on contentious tax issues. Giles leads an excellent technically strong team who are all very pleasant to deal with.’

          ‘Giles Salmond is the go to tax litigator and his technical expertise and know how – both in terms of direct and indirect tax matters is second to none.’

          ‘The Tax Litigation and Investigations team is extremely strong. They are prepared to go the extra mile to support their clients. They will make time at unsociable hours of the day to ensure that a client’s needs a met. Even when not in the office they are available. In my experience, it compares very favourably compared to other firms. They have also embraced a hybrid form of working which they deploy in every case. Where appropriate they ensure face to face meetings still happen, but to save client’s time and money if it doesn’t need to be face to face they do not insist on doing so.’

          ‘Giles Salmond and Ed Griffiths are brilliant. They are permanently contactable and incredibly clever. They are thorough individuals who do not let anything slip by them. They have been involved in, and run, incredibly complicated investigations to support their clients who have been accused of serious criminal activity. I cannot speak highly enough in support of them.’

          Key clients

          PriceWaterhouseCoopers LLP

          Aozora GMAC Investments Limited

          Work highlights

            Hogan Lovells International LLP

            Hogan Lovells International LLP has an extensive tax litigation and investigation offering with expertise in the tech, insurance and real estate sectors. The practice are known for HMRC enquiries and internal investigations with a number of US groups among the client base. Rupert Shiers leads the UK and European tax litigation team with expertise in taxpayers rights, HMRC powers and tax statutory interpretation.

            Practice head(s):

            Rupert Shiers

            Work highlights

            • Advised Fortune 500 and FTSE 100 defined benefit pension schemes on resolving their position in multi-party VAT litigation, actively managed by the Tribunal.
            • Advised Eynsham Cricket Club on Court of Appeal VAT litigation, addressing zero-rating, interaction of VAT and fundamental points of statutory interpretation.

            Mishcon de Reya LLP

            The tax disputes and investigations team at Mishcon de Reya LLP spans both indirect and direct tax with both corporate and private clients. ADR and mediation continues to be a key focus of the teams practice as the practice advises on all aspects of dispute resolution from early stage written representations through to a Tribunal hearing. Team head Leslie Allen is experienced in the conduct of indirect disputes and is supported by Robert Hartley who advises clients across the real estate and leisure sectors. Paul Noble specialises in resolving complex tax disputes.

            Practice head(s):

            Leslie Allen

            Other key lawyers:

            Robert Hartley; Paul Noble

            Testimonials

            ‘Mishcon’s tax team is right at the top of the tree. They are involved in the most important and high value cases in this area. They have strength throughout their team.’

            ‘Leslie Allen has years of experience. He is excellent to work with, and is both clever and pragmatic.’

            ‘We have used Mishcon for specialist tax advice regarding a dispute with HMRC for which they have the appropriate skills, knowledge & experience.’

            ‘Mishcon is unusual in that it has a specialist tax litigation team and the tax department is fully integrated with the litigation team – an arrangement that works admirably. Mishcon is one of only a handful of firms with a disputes practice which spans both indirect and direct tax, for both corporate and private clients, as well as civil and criminal investigations, in contrast with those tax teams who cannot turn their hands to disputes. We have enjoyed working closely with Mishcon very much.’

            ‘The team possesses a number of extremely sharp minds. Things get done quickly and well. There is great cohesion between members of the litigation team and an informality which allows the free exchange of ideas irrespective of seniority.’

            ‘Their attention to detail, willingness to engage in a debate in order to explain and explore the options available, matched with a comprehensive understanding of the subject matter.’

            ‘Very approachable and reliable in all dealings.’

            Key clients

            Royal Mail Group Litigation

            Zipvit Ltd

            Iceland Foods Limited

            Work highlights

            • Represented over 300 corporate entities and local authorities against Royal Mail.

            Norton Rose Fulbright

            Norton Rose Fulbright has extensive experience in advising taxpayers in relation to tax authority investigations, negotiations with tax authorities, public law remedies and matters before the major UK courts and tribunals. The team also carries out work with an international element including challenges to international group structures and tax residence. Practice head Dominic Stuttaford is an experienced tax litigator while Chris Bates is regularly instructed on HMRC investigations. Michael Alliston advises taxpayers on tax governance and compliance matters.

            Practice head(s):

            Dominic Stuttaford

            Other key lawyers:

            Chris Bates; Michael Alliston

            Testimonials

            ‘A down to earth and super dedicated and talented team with great reputation, standing and industry knowledge.’

            ‘A stand out team that offers great client centered and commercial advice combined with the outstanding legal skills of a leading City law form.’

            ‘I have worked with Dominic Stuttaford, partner, on many occasions and admire his great experience, knowledge and manner.’

            ‘Dominic Stuttaford has a brain the size of a planet, and what he doesn’t know about tax law isn’t worth knowing. It’s impossible not to feel in awe when he explains a complex tax statute or authority with such ease and simplicity. He’s a stunningly impressive tax practitioner.’

            ‘Aditya is a stunningly impressive solicitor, he works terrifyingly hard and produces breathtakingly well-analysed documents. If I could have him on every one of my cases I’d be delighted. Top quality.’

            Key clients

            BMW

            HSBC

            Lloyds Banking Group

            Takeda

            Royal Bank of Canada

            DP World

            Work highlights

            • Acted for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.
            • Acted for Takeda in a restitution claim in the Stamp Taxes Group Litigation Order relating to Stamp Duty Reserve Tax.
            • Acted for Royal Bank of Canada in relation to a dispute with HMRC concerning the taxation of North Sea Oil royalties.

            Stewarts Law LLP

            Stewarts Law LLP acts on a multi-disciplinary basis across four specialist areas of tax disputes including direct tax litigation, indirect tax litigation, tax investigations and commercial tax litigation. The department is well-versed in tax and HMRC settlement with a diverse client base from high-net worth individuals and associated businesses. David Pickstone  is experienced in direct tax, environmental tax and commercial tax litigation. Lee Ellis acts for corporates while Victor Cramer  focuses on indirect tax.

            Practice head(s):

            David Pickstone

            Other key lawyers:

            Lee Ellis; Victor Cramer

            Testimonials

            ‘Excellent relationship with HMRC which assists clients in getting to heart of dispute quickly. Former HMRC senior officers on the team help understand HMRC thinking. Very accessible and responsive partners.’

            ‘Partner Lee Ellis has exceptional grasp of complex and technical issues, leverages his in house experience at HMRC Solicitors Office wisely and gives clients great insight into the mindset of Revenue.’

            ‘Stewarts key strengths are their extensive experience and in-depth knowledge of tax litigation which enables them to give insightful, pragmatic and exceptional strategic advice in addition to first class technical tax advice. This in my view is what makes the team stand out from other legal advisers.’

            ‘Lee Ellis has extensive experience of both tax advisory and tax litigation both from an HMRC and taxpayer perspective. This enables him to give taxpayers exceptionally astute, strategic and pragmatic advice on all all stages of tax investigations and tax litigation more generally. In addition to being an exception technical tax lawyer, he also has exceptionally sound judgement and is strategically astute.’

            ‘Excellent team with excellent leadership from David. technically very capable lawyers, approachable and easy to work with.’

            ‘David Pickstone is noted for his technical ability and leadership skills’

            ‘Strong litigation team combined with technical knowledge.’

            ‘I have recently worked with Victor Kramer and Krishna Mahajan, and they were both excellent – communicative, practical, technical and commercial.’

            ‘Strong litigation team combined with technical knowledge.’

            Key clients

            Quinn (London) Ltd

            The Claims Guys Ltd

            Tayto Group Limited and Others

            FCC Recycling UK Limited and Singleton Birch Limited

            John Jaekel

            Marchill Investments LLP

            A Banking & Finance Industry Body

            Neil Blair / The Blair Partnership

            Work highlights

            • Acted Quinn (London) Ltd in a leading tax appeal which found for our clients and rejected HMRC’s attempts to narrow the scope and availability of R&D relief to small and medium-sized enterprises.

            Weil, Gotshal & Manges (London) LLP

            The tax litigation team at Weil, Gotshal & Manges (London) LLP is 'thorough, efficient, organised and all-round great to work with‘. The practice frequently advises clients on the merits of pursuing litigation against tax authorities and the interaction between insurance cover and the decision to settle a claim. The firm’s key lawyers include disputes expert Jamie Maples , Jenny Doak and Oliver Walker who advises private equity and pension funds. Chris Marks regularly advises clients in relation to pre-dispute strategy.

            Practice head(s):

            Oliver Walker; Jenny Doak; Jamie Maples; Christopher Marks

            Testimonials

            ‘Working with this team, what marks them out is their clarity of instruction and commercial acumen.’

            ‘I found their instructions clear and well reasoned and the case was well prepared.’

            ‘The associate I have worked closely with is Stuart Pibworth, a very bright person with good judgment and a commercial manner.’

            ‘International approach to the business, very skilled individuals within the teams, capable of handling complex matters efficiently.’

            ‘London team are great to work with, very capable but easy to work with.’

            ‘Truly exceptional in terms of client care. Dedicated and know their stuff, inside out.’

            ‘Hayley Lund. The hardest working litigator I’ve ever met. She is an investigation specialist – and will almost certainly end up being the go to lawyer in that field. She knows a frightening amount about tax investigations, with an impressive practice in that field.’

            ‘The team at Weil is fantastic. They are thorough, efficient, organised and all-round great to work with.’

            ‘The Weil tax team consistently display excellent client service, exemplified by an ability to explain complex contractual matters to non-lawyers in a clear, concise, and commercial manner. They are always accessible and very responsive, and work well in conjunction with their commercial colleagues.’

            Key clients

            Littlewoods Group

            Joint Special Administrators of MF Global UK

            Advent International

            Providence Equity Partners

            Bark&co

            Bark&co has expertise in civil tax and criminal tax fraud with an increasing focus on litigation in areas of VAT and excise duty. Giles Bark-Jones leads the practice with expertise extending to several areas of civil litigation including fraud and contentious tax. Peter Finbow specialises in white-collar crime including VAT fraud and money laundering.

            Practice head(s):

            Giles Bark-Jones

            Other key lawyers:

            Peter Finbow

            Testimonials

            ‘In my view, Bark and Co is one of the pre-eminent firms in both areas of criminal practice (fraud and general crime) with great strength and depth in the team. They also have a very effective tax/civil department that compliments what they do, particularly with regard to fraud.’

            ‘As stated above the firm has great strength and depth. I would wish to single out Giles Bark-Jones who remains the back bone of the firm and very much in control of the whole show. He is an excellent lawyer and very much the power house that drives the firm forward and ensures that it provides the excellent quality of service that it does.’

            ‘Bark & Co’s is one of the leading boutique white-collar crime firms, with particular experience of investigations and prosecutions relating to tax frauds, meaning that they have a wealth of expertise in dealing with tax investigations and the litigation that flows from it.’

            ‘Giles Bark-Jones is still one of the real heavyweights. He is actively involved in client management and providing high-level strategic and tactical advice. Clients really know that he is on their side.’

            ‘Peter Finbow is someone who provides a reassuring presence in any case. He has excellent instincts, and is adept at spotting and resolving issues long before they become a problem.’

            ‘Maria Stalbow gets under the skin of a case and has a knack of getting straight to the heart of the case. Clients like her and she’s always on top of the detail.’

            ‘One of the top firms in london with a series of great work and high profile cases.’

            ‘Similar to their white collar crime offering, the firm excel in their offering to clients in the tax litigation and investigations market. They are becoming full service for contentious criminal/civil cross over work, an area of work which we are seeing a large increase of volume in over the last few years.’

            ‘Paul Lennon is standout in this area. He has a big following in the financial crime market and this complements this part of his practice’

            Work highlights

            • Acted for an individual in investigations by the National Crime Agency and SKAT into fraud and money-laundering activities worth over £1.5bn committed against the tax authorities in a number of European countries.
            • Acted for one of a number of individuals alleged to have been part of an OCG into which HMRC conducted an intensive investigation concerning a long-running conspiracy to cheat the public revenue along with ancillary money laundering offences.
            • Acting for one of a number of individuals charged in relation to an alleged alcohol diversion fraud operated on a massive scale in 2009 and 2010.

            BCL Solicitors LLP

            The business crime and regulation team at BCL Solicitors LLP acts for a range of clients including high-ranking executives and senior figures. The firm has expertise in tax fraud cases across the financial and legal sectors. Co-head Harry Travers combines experience in tax litigation and tax fraud. Other co-heads Ian Burton and Greg Mailer are involved in tax investigations while John Binns represents individual and corporate clients.

            Practice head(s):

            Harry Travers; Ian Burton; Greg Mailer

            Other key lawyers:

            John Binns

            Testimonials

            ‘Unparalleled expertise in the financial crime space. Consistently delivering outcomes above and beyond those that could be reasonably anticipated.’

            ‘Harry Travers combines a very powerful analytical mind, with deep technical skills and industry leading experience. Harry works tirelessly to ensure clients benefit from the best possible outcomes in the hazardous environment of serious tax investigations.’

            ‘Greg Mailer has strong technical skills and is a very skilled negotiator and problem solver. Greg is a very safe pair of hands in the daunting environment of serious tax investigations.’

            ‘This is a highly capable team with an ability to get up to speed on technical tax points and to handle difficult investigations. It has excellent relations with HMRC and is highly strategic.’

            ‘Harry Travers is extremely competent, quick and thorough. Umar Azmeh – very thorough, diligent and user friendly.’

            ‘BCL have an amazing client base which is a testament to the quality of the work they do. They appear to be the firm of choice for high profile clients where there is a lot at stake (criminal and/or civil), which reflects a long standing history of achieving the best results.’

            ‘Ian Burton is exceptional. He has the ability to build and maintain excellent relationships with both the client and HMRC, inspiring confidence on both sides.’

            ‘Harry Travers is a comforting and intelligent presence.’

            Work highlights

              Charles Russell Speechlys LLP

              Charles Russell Speechlys LLP are known for their ability to offer expert advice on HMRC enquiries, investigations and litigation including claims for mistake and rectification both in the UK and offshore. Hugh Gunson heads the practice and covers the full spectrum of work including corporation tax and CGT.

              Practice head(s):

              Hugh Gunson

              Testimonials

              ‘Excellent attention to detail and commerciality.’

              ‘Hugh Gunson has shown a very pragmatic and commercial approach and his attention to detail is highly impressive, which inspires confidence in his handling of affairs.’

              ‘This is a technically excellent and highly responsive team. The tax litigation team was able to work seamlessly with the private client team to provide a joined up offering.’

              ‘Hugh Gunson was highly knowledgeable, technically excellent and very responsive. He provided invaluable strategic input in a complex matter and was very good at presenting matters to the client so that they felt fully informed as to and involved in the process.’

              ‘A very good technical grasp of tax both in terms of traditional trust and personal issues and highly technical corporate taxation.’

              ‘The team showed great responsiveness and willingness to engage with a new client. They brought practical thinking to a transaction, and recognised the client’s need for a straight forward solution.’

              ‘Hugh Gunson made himself available for the client and took a collaborative approach to working with other professional advisors, with a focus on a the strong outcome for the client.’

              ‘We have been engaged to assist the CRS team with the accounting and numerical aspects of a major tax disclosure, complementing the clearly demonstrated technical expertise and excellence of the team.’

              Key clients

              Nicola Mackay

              Work highlights

              • Acted for Nicola Mackay in an application to the High Court to set aside her appointment as trustee of a trust on one of a number of grounds.
              • Advised a client in relation to a very complex and high value disclosure to HMRC in relation to unpaid tax liabilities and a related professional negligence claim.
              • Advised three brothers in relation to an HMRC investigation under Code of Practice 9 (COP 9) into their personal tax affairs, involving high value offshore trusts.

              Kingsley Napley LLP

              Kingsley Napley LLP represents individuals in cases involving allegations of tax avoidance and indirect taxation matters such as VAT claims and settlements. The firm also has a good reputation for advising on high-profile tax fraud cases and white collar crime. The key names include financial crime expert David Sleight and Louise Hodges, who frequently handles tax investigations. Ed Smyth acts for individuals and corporates in respect of criminal cases.

              Practice head(s):

              Waqar Shah

              Other key lawyers:

              Ed Smyth; Louise Hodges; David Sleight

              Testimonials

              ‘The team at KN has an incredibly client focused approach, the client is always number one. The team is always thinking about what is best for the client, how issues can be best communicated and how they can put together the right group of professional representatives. The pursuit of excellence in this way is massively reassuring for clients and gives them real confidence that their case is being dealt with properly and promptly.’

              ‘The team also has lawyers of the highest quality, who seek to learn and get better at what they do.’

              ‘They are just so impressive and I would recommend them to anyone.’

              ‘David Sleight is a star individual who really gets how the client is feeling and what he needs to do to put them at ease. He is also a top lawyer and a superb tactician. He can see many steps ahead which allows him to cut through even the most difficult cases with ease. I regard him as one of the pre-eminent lawyers in this work space and I can only see him becoming better and better over the next 5-10 years.’

              ‘KN have a solid reputation in all areas of financial crime and a growing reputation in tax investigations.’

              ‘A strong team which has considerable experience in dealing with individual tax problems.’

              ‘Waqar Shah is first rate and a future leader is this field. He is very client-friendly and achieves excellent results.’

              Work highlights

                Kuit Steinart Levy LLP

                The tax investigations team at Kuit Steinart Levy LLP represents clients in  relation to a  range of issues including tax scheme investigations, furlough fraud, settlement of scheme liabilities and cases involving tax data theft. Practice head Robert Levy  has expertise in representing clients facing tax investigations while Paul Bricknell specialises in tax disclosure matters.

                Practice head(s):

                Robert Levy

                Other key lawyers:

                Paul Bricknell; Wendi Bussin

                Testimonials

                ‘Knowledge, experience and client care from a team who really put their clients’ best interests first. We have worked alongside this team and they are impressive.’

                ‘The firm is well known in this area with good technical tax knowledge and known for excellent client care.’

                ‘Robert Levy is popular, collegiate, technically able, experienced and strategically astute.’

                ‘Wendi Bussin is also well regarded and has excellent client handling skills.’

                ‘Great interpersonal skills with a focus on developing a collaborative approach to working on wide ranging issues. Highly regarded as a ‘go to’ law firm.’

                ‘Robert Levy has a great depth of experience and is a pleasure to work with. Easily approachable and has a strong focus on building relationships to resolve complex and wide ranging issues.’

                ‘Wendi Bussin is a stand out performer Her knowledge of the law is first class Client friendly and very commercial aware’

                ‘Customer focus, personalised approach. Responsive to any type of client inquiry. Very personal.’

                Work highlights

                  Osborne Clarke LLP

                  Osborne Clarke LLP often advises on tax related litigation matters with expertise in the off payroll and flexible workforce sector. The team is especially active in the technology and financial services sector. Ian Hyde leads the team and represents clients in all aspects of tax risk and tax litigation. Frances Lewis is experienced in advising staffing companies on tax status issues.

                  Practice head(s):

                  Ian Hyde

                  Other key lawyers:

                  Frances Lewis

                  Testimonials

                  ‘This is a tightly-focused team, able to deliver in relation to tax disputes and advisory matters across all taxes. Great at collaborating and innovative in relation in particular to disputes work and Alternative Dispute Resolution with HMRC.’

                  ‘Ian Hyde in particular is a standout individual. He is a part-time tribunal judge and CEDR-accredited mediator as well, so he has real insight to offer in terms of dispute resolution with HMRC and how a court or tribunal might view any given case. He is personable and efficient, as well as being a technical expert.’

                  ‘Ian Hyde combines technical knowledge with a real feel for litigation.’

                  ‘The team are very technically able, friendly and commercial.’

                  Key clients

                  UBS AG

                  Domino’s Pizza Group PLC

                  Npower

                  Work highlights

                  • Represented a client in an appeal to the Tax Tribunal following HMRC’s investigation into the historic VAT recovery and partial exemption position.
                  • Advised an accountancy service company in HMRC’s investigation into the application of the Managed Service Company anti-avoidance legislation to a structure for managing self-employed contractors.
                  • Advised an international recycling group on an HMRC investigation into treatment of import and export of recycled automotive parts and whether the exports to Europe qualified for zero rating.

                  Peters & Peters Solicitors LLP

                  Peters & Peters Solicitors LLP‘s tax team specialises in civil and criminal disputes with extensive experience in handling investigations and liaising with HMRC. Many of the firm’s cases have an international element such as overseas tax law or offshore tax structures. Practice head Neil Swift has expertise in criminal tax fraud and civil cases. Maria Cronin provides clients with advice in FCA and money laundering matters.

                  Practice head(s):

                  Neil Swift

                  Other key lawyers:

                  Maria Cronin

                  Testimonials

                  ‘The practice seem to show true understanding and compassion for my situation and I felt went above and beyond, day or night to put my mind at ease.’

                  Key clients

                  High Profile entrepreneur

                  Two Chinese citizens and their company

                  Work highlights

                  • Acted for two Chinese citizens and their UK incorporated company in a large-scale money laundering investigation.

                  Skadden, Arps, Slate, Meagher & Flom (UK) LLP

                  The European tax controversy group at Skadden, Arps, Slate, Meagher & Flom (UK) LLP resolves high-value matters for clients that include corporations, partnerships, estates, individuals and government entities. The team has experience in areas such as transfer pricing, case-management for EU-related tax and state aid claims. James Anderson co-heads the practice with David Kavanagh who has expertise in litigation and arbitration.

                  Practice head(s):

                  James Anderson; David Kavanagh KC

                  Testimonials

                  ‘Skadden, Arps, Slate, Meagher & Flom was instrumental in fielding a counterclaim in an arbitration where they did literally “dig out” tax and financial information hidden by the Claimant.’

                  ‘David Kavanagh had a superb grasp of the financial and tax implication of the obvious and non-obvious aspects of the case.’

                  ‘Strong consistent team with deep knowledge in their specialism and of our business.’

                  ‘Great balance of technical vs practical advice. Easy to work and have open discussions with. Very quick to turnaround requests. Our team consists of James Anderson and Alex Rigby.’

                  Key clients

                  Vodafone International Holdings BV

                  Kingfisher plc

                  Victaulic Europe BV

                  Megapolis

                  Anadarko

                  Work highlights

                  • Represented Vodafone in its $5.5 billion dispute with India in one of the most high-profile bilateral investment treaty (BIT) disputes.
                  • Acted as state aid counsel for Kingfisher plc in connection with the European Commission’s investigation into the group financing exemption in the UK’s former controlled foreign company (CFC) rules.