Firms To Watch: Tax litigation and investigations

In summer 2021 DLA Piper made a notable hire in London with the appointment of highly experienced contentious tax lawyer Jason Collins as head of its international tax disputes practice. Stuart Walsh and Clara Boyd joined in August 2022.
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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 a 'class outfit' with a team of 'highly competent experts'. The practice is a one-stop shop for contentious tax advice with expertise in handling direct business tax disputes, personal tax disputes, employment tax disputes and more. The team displays a broad range of industry expertise that covers the energy, financial services, real estate and TMT sectors. Practice head Nick Clayton 'inspires confidence in clients' and has extensive experience of handling tax investigations and disputes. Dual-qualified solicitor and accountant Michael Hunt advises on employment-related tax issues. Heather Gething retired in December 2020.

Practice head(s):

Nick Clayton

Other key lawyers:

Michael Hunt; Dawen Gao

Testimonials

Experienced department. Very responsive to client requests. Good planning of cases and presentation.’

Nick Clayton – Inspires confidence in clients. Deep understanding of legal issues. Strong in tactics. Calm approach is appreciated by clients.’

The team has been supportive, competent, strong in terms of resource allocation and readily available.’

Individuals have all been very professional and timely with response/document preparation and submission.’

Tax litigation team are highly competent experts able to offer strategic and cogent advice.’

A class outfit and an effective organisation with a depth of talent. The engine room for UK commercial tax litigation.’

Michael Hunt – A very polished and hard-edged individual. Always delivers the right result for the client and takes a commercial view on matters.’

Key clients

Uber

UBS

Bernie Ecclestone

PacifiCorp

Joseph Hage Aaronson LLP

Dispute resolution boutique Joseph Hage Aaronson LLPComparative Guides promotional icon specialises in tax litigation, commercial litigation and international arbitration. The team, which is 'totally solution-focused' and is 'second to none', primarily represents multinational companies in complex and cross-border tax disputes. It notably distinguishes itself in relation to corporate tax group litigation orders. Graham Aaronson KC co-heads the practice with fellow founding partner Michael Anderson, with the latter practitioner having extensive tax litigation experience at all levels of the UK’s tax tribunals. Simon Whitehead, who has an exclusive contentious tax disputes practice, focuses on direct and corporate tax. European tax law expert Paul Farmer, Emma Chamberlain and Shofiq Miah  are also noted. Key changes to the team included the arrival of Iain MacWhannell from Memery Crystal LLP in February 2021.

Practice head(s):

Graham Aaronson KC; Michael Anderson

Other key lawyers:

Simon Whitehead; Paul Farmer; Daniel Margolin KC; Emma Chamberlain; Shofiq Miah; Iain MacWhannell

Testimonials

They simply know what they are doing and have good coverage within the team and you always have access to the partners. The billing is timely, clear and transparent.’

Simon Whitehead and Michael Anderson; They will always find a solution to any legal obstacle that comes up. They ensure that every possible angle is covered, to ensure that they try and stay one step ahead of the authorities where they can.’

JHA’s professional knowledge in the the arena of dispute resolution/tax litigation and investigations is second to none. A particular strength is their ability to distil complex legal technicalities into relevant and understandable principles Importantly they apply that knowledge with an outcome-focused pragmatism . . all members of the team are totally solution-focused.’

Shofiq totally embodies all the principles of the firm and can also be relied on to ‘cover all the bases’ thoroughly and reliably. In addition, Shofiq consistently delivers a highly responsive level of ‘customer service’ in all his dealings.’

One of the best in tax litigation as a result of many years of successful results. In my opinion, no other firm comes close!

Key clients

British American Tobacco

Marks & Spencer

Prudential

Intercontinental Hotels Group

Richemont

Akzo Nobel

GKN

Fidelity

JJ Management LLP

NMC Logistics Ltd

Work highlights

  • Acting as lead solicitors in the FII GLO, advising 25 UK headquartered multinationals challenge the UK’s dividend taxation scheme and the imposition of advance corporation tax (‘ACT’) upon UK groups with their sources of profit abroad.
  • Advising Fidelity on a reference to the European Court (C-480/16 Fidelity Funds) from the Danish court and ongoing litigation in the Danish courts where JHA continue to act as co-counsel advising on issues of EU law.
  • Commenced an action by a group of 16 multinational companies led by BAT, challenging the lawfulness of a “supertax” legislation.

Pinsent Masons LLP

Pinsent Masons LLP‘s team combines ‘technical ability with litigation expertise‘. The practice has deep financial services sector expertise and acts as long-term advisers to a variety of global financial institutions. Other areas of focus include advising clients on compliance with the IR35 legislation, the Criminal Finances Act 2017, Diverted Profits Tax, employment and business crime tax-related issues. Steven Porter leads the contentious tax team and is praised for his ‘exceptional‘ client service. Clients also describe legal director Jake Landman as ‘a force to be reckoned with‘. Other key individuals to note include Andrew Sackey and Ian Robotham. Global head of tax Jason Collins recently left the firm to join DLA Piper, as did Stuart Walsh and Clara Boyd in August 2022.

Practice head(s):

Steven Porter

Other key lawyers:

Andrew Sackey; Jake Landman

Testimonials

The Pinsent Masons LLP tax litigation team is the leading commercial tax disputes team in London. They combine technical ability with litigation expertise and are at the cutting-edge of market developments in the field.’

Jake Landman is a force to be reckoned with: he combines deep technical knowledge and attention to detail with a focused determination to get the right result.’

Steven Porter is exceptional in the service that he provides.’

‘Steven Porter is always ahead of the game; seems to know what the opposition will do before they do.’

Key clients

NatWest Group

BT Pension Scheme

Coal Superannuation Scheme

Raymond Tooth

Cantor-Fitzgerald

E-Zec Medical Transport Services

Work highlights

  • Advised NatWest Group on an £86m VAT dispute, with the potential for a further penalty up to 100% of the VAT, which is currently before the First-tier Tribunal (Tax).
  • Advising on the MOD’s group action, which includes British Coal who is a lead claimant for the pension funds involved in this litigation which comprises of over 40 of the UK’s largest companies, who are challenging a discriminatory UK WHT suffered on certain income derived from lending non-UK shares.
  • Acting for Raymond Tooth before the Court of Appeal in HMRC v Raymond Tooth [2019] EWCA Civ 826 in which the firm successfully argued that HMRC could not rely on extended discovery assessment time limits.

Slaughter and May

Slaughter and May's 'excellent tax team' demonstrates 'a real commitment to the client's case'. Key cases that the team have advised on involve a broad range of tax areas, including bank payroll tax, management incentivisation arrangements and transfer pricing, as well as diverted profits tax ('DPT'). Dominic Robertson, who has a strong background in DPT and transfer pricing, co-heads the tax disputes practice with Richard Jeens. Corporate tax specialist Mike Lane and Steve Edge are key individuals. Ewan Brown and William Watson are also noted. Sarah Lee and Sara Luder retired in 2020.

Practice head(s):

Richard Jeens; Dominic Robertson

Other key lawyers:

Ewan Brown; William Watson; Mike Lane; Sarah Osprey

Testimonials

Strong team, excellent talent, good spread of resource. Delivers when it counts.’

William Watson technical expertise is second to none.’

Slaughters have always had an excellent tax team, and the current team continues this tradition. In terms of knowledge and skills they are certainly one of the top teams in the country.’

Apart from knowledge of tax law, the individuals I have dealt with have shown a real commitment to the client’s case.’

Key clients

BlueCrest

Coca-Cola European Partners

Credit Suisse

GDF Suez Teesside

GlaxoSmithKline

Hays

Mercuria Energy Europe Trading

Mr. William Reeves

Vodafone

Work highlights

  • Acted for Credit Suisse in its dispute with HMRC concerning technical issues in respect of the application of the Bank Payroll Tax legislation.
  • Advising BlueCrest on conjoined appeals in relation to (i) challenges to the UK tax treatment of its management incentivisation arrangements and (ii) the tax treatment of a high value buyout of the partnership stake of one of BlueCrest’s founding partners.
  • Advising GSK and Vodafone on their appeals against 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 tax team has ‘high quality individuals‘ with ‘considerable experience of complex tax issues. Its work covers all aspects of tax disputes, including pre-litigation advice and negotiations with HMRC, and court proceedings and investigations. The practice is notably active in sectors such as financial services, consumer, retail, energy and transport. Vimal Tilakapala, who heads up the UK tax practice, has extensive experience of handling finance-related tax issues. Chris Harrison, who also has a strong background in finance, assists clients with structured finance transactions. Another key individual is corporate tax lawyer Lydia Challen, who advises on M&A, corporate reorganisations and private equity tax. The ‘hardworking‘ Charles Yorke is highlighted for his expertise in the financial services, oil and infrastructure sectors.

Practice head(s):

Vimal Tilakapala

Other key lawyers:

Charles Yorke; Lydia Challen; Chris Harrison

Testimonials

The A&O team are good lawyers, with considerable experience of complex tax issues and their resolution, either by negotiation and settlement or through litigation. At all times when I have dealt with them they have shown sound technical knowledge and a strong sense of their clients.’

They are a formidable team, both technically and tactically.’

The team has high quality individuals and works very hard for their clients. Charles Yorke is very bright with a good grasp of the detail.’

Key clients

Investec

PwC

Ashurst

Ashurst has a 'formidable tax litigation' practice, particularly in the areas of VAT litigation, indirect tax, employment taxes and EU state aid. Clients praise the team for being 'utterly professional', 'hardworking and technically knowledgeable'. Key industries of expertise include financial services, energy, resources, infrastructure and real estate. Practice head Nicholas Gardner is 'extremely good' at handling disputes involving HMRC and his practice covers both direct and indirect taxation, as does Alexander Cox, who is 'very highly recommended' and 'commercial'. Cox has particular expertise advising on the tax aspects of fund formation, M&A, private equity, corporate disposals and reconstructions. Paul Miller has strong financial services industry expertise. Senior associate Sara Mardell is another key individual.

Practice head(s):

Nicholas Gardner

Other key lawyers:

Paul Miller; Alexander Cox; Sara Mardell; Shayaan Zaraq Bari

Testimonials

Alex Cox is very highly recommended. He is commercial, thinks outside the box, has in-depth technical knowledge across the taxes. He is also a pleasure to work with.’

The team we deal with is hardworking and technically knowledgeable, but they also advise with regard to the wider context of a scenario. This results in advice that is pragmatic and useful, rather than being just what the letter of the law says.

I have worked with Nicholas Gardner, partner, on two significant cases: one in the First-tier Tax Tribunal and the other in the Supreme Court. Nick was extremely good, both at dealing with significant volumes of documents and evidence and at navigating complex procedural rules.’

Utterly professional. One of the most formidable tax litigation teams operating in the market today. Their attention to detail and commitment to the case is astounding; illustrated by their level of success. They are an absolute joy to work with.’

Nick Gardner and Alex Cox, both partners in the tax team, have phenomenal technical knowledge. They also lead the team by example; they have a tireless work-ethic and will ensure that nothing is left to chance. Availability is never an issue, and their experience brings real value to the team. Sara Mardell, a senior associate in the tax team, is almost certainly a star of the future. She stands head and shoulders above her peers. She inspires confidence in both clients and the rest of the team.’

A really detailed and intelligent appreciation of the workings of the tax tribunals with great resources and an in depth knowledge and expertise in tax – great combination.’

Paul Miller and Sara Mardell are an excellent team. Clever, practical, totally reliable.’

Key clients

London Clubs Management

Imperial Brands PLC

Thomas Cook Group – Hotels 4 U

The legacy Gala Coral companies

Ocean Finance

Hastings Insurance Services Limited

Oxford Instruments

Work highlights

  • Advising London Clubs Management on resisting HMRC’s application to appeal to the Supreme Court in a case involving gaming duty.
  • Acting for Ocean Finance in relation to proceedings brought by HMRC which explored the scope VAT abuse.
  • Advising Imperial Brands PLC on challenging the EC’s decision that the UK CFC regime was unlawful state aid and that the UK should recover the benefit of the state aid.

Baker McKenzie

Baker McKenzie's tax team is 'fantastic' and displays 'excellent technical knowledge', particularly in the financial services, healthcare, TMT and consumer goods industries. Economist Nigel Dolman, who heads up the transfer pricing disputes practice, specialises in defending global transfer pricing and and valuations for multinationals. Senior tax litigator Jessica Eden leads the corporate tax disputes work and has extensive experience of HMRC investigations. David Jamieson is the head of the VAT/indirect tax disputes team and handles VAT disputes for clients in financial services, telecommunications and e-commerce sectors. Another key name to note is Kate Alexander, who has a broad UK and international taxation practice.

Practice head(s):

Nigel Dolman; David Jamieson; Jessica Eden

Other key lawyers:

Mark Delaney; Kate Alexander; Richard Fletcher; Mark Agnew

Testimonials

The team at Baker McKenzie have excellent technical knowledge and a good sense of the need to advance their clients.’

I have dealt most with Jessica Eden and Kate Alexander, both partners, who are exceptionally bright tax lawyers with good negotiating skills and a sound grasp of case strategy. They are a fantastic team, both technically and tactically.’

Great people to work with. Knowledgeable and responsive. Strong technical knowledge coupled with an understanding of our industry.’

Bakers has skilled lead partners and very capable associates. The firm has significant practices in various important countries, and those practices have good connectivity. This multijurisdictional capability is crucial in handling cross-border disputes. Bakers has a real competitive advantage with having a powerful economics practice in-house.’

Key clients

Baker Hughes

Core Media

Electronic Arts

European Tyre Enterprise Limited

Hutchison 3G Limited

Marriott

MDU (Medical Defence Union Limited)

Thames Television

UK Power Networks

Work highlights

  • Acting in a case for UK Power Networks defending claims for consortium relief.
  • Advising the Kwik Fit Group on a long running dispute with HMRC over interest deductibility (unallowable purpose).
  • Acting for the Medical Defence Union (the MDU) in an appeal to Upper Tribunal concerning tax treatment of return of premium to a mutual trade.

Bryan Cave Leighton Paisner LLP

Bryan Cave Leighton Paisner LLP's strengths in tax litigation are complemented by its advice to clients on HMRC investigations. Elizabeth Bradley is the global head of tax at the firm. Kate Ison, who has an exclusive focus on contentious tax work, is 'excellent' and has a 'fantastic legal mind'. Alan Sinyor leads the VAT practice and advises on the full spectrum of excels in covering the full spectrum of contentious and non-contentious VAT issues; he has a 'brilliant mind' and is in a 'league of his own'. Mukul Chawla KC has a strong background in fraud and white-collar crime.

Practice head(s):

Elizabeth Bradley

Other key lawyers:

Kate Ison; Alan Sinyor; Mukul Cawla KC

Testimonials

A highly able and engaged team, with extensive experience of dealing with and resolving disputes with HMRC.’

Kate Ison is excellent. Clear, very able and good to work with.’

Alan Sinyor is in a league of his own. Brilliant mind, Outstanding execution.’

The team is a juggernaut who can take on HMRC and win. Well-resourced, client-friendly and intellectually rigorous lawyers.’

Kate Ison – a fantastic legal mind and perfectly placed to lead complex tax litigation.’

Key clients

Vaccine Research Limited Partnership

Work highlights

  • Advised a major corporate on an appeal against SDLT assessments in the amount of £30m.
  • Advising a global financial services firm on an investigation into suspected tax –related fraud.
  • Advising a multinational group on the risks of HMRC challenge as to corporate tax residence as a result of COVID-19 related travel restrictions.

Clifford Chance LLP

Clifford Chance LLP showcases expertise in handling complex international and cross-border tax investigations and litigation, including indirect and VAT disputes. Dan Neidle has a strong background in financial institution taxation and advises clients on a broad range of tax disputes and transactions. David Saleh acts for a large client base of multinational corporations and financial institutions. David Harkness has in-depth expertise advising on UK and international tax disputes.

Practice head(s):

Dan Neidle; David Saleh; David Harkness

Fieldfisher

Fieldfisher handles a wide range of tax issues, covering civil and criminal investigations, tax litigation and tax-related professional negligence claims. Practice head Derek Hill has a well-established presence in the media and film space and advises on all tax-related issues. He co-heads the practice with George Gillham, who is highlighted for his 'sensible' advice. In-house barrister Philippe Freund specialises in contentious tax and has a strong UK and international tax practice. Matthew Sharp is 'impressive' and 'a pleasure to work with'.

Practice head(s):

Derek Hill; George Gillham

Other key lawyers:

Philippe Freund; Matthew Sharp

Testimonials

Fieldfisher are a superb firm specialising in dispute resolution and tax litigation.’

Derek Hill is a partner with a background steeped in tax matters who is able to grapple with hugely complex documentation and produce lucid, compelling arguments which HMRC find challenging to meet. Definitely someone to have on your side rather than against it. George Gillham is a very experienced litigation partner, definitely a safe pair of hands, providing realistic and sensible advice to his clients.’

George Gilham, has good experience in both criminal and civil cases which makes him an excellent choice in a tax investigation case, hard working, good with clients, knowledgeable.’

Philippe Freund is an outstanding tax lawyer who renders extremely practical advice to solve issues. This advice is based on the knowledge and experience of a Barrister who knows what the outcome of litigation might be. Fluent in English, French and German -even with a German legal education- he is the lawyer of choice for cross-border or international tax matters.’

Matthew Sharp – he is impressive on the technical and factual detail and very responsive. A pleasure to work with, as he combines technical ability with common sense and good judgment. Straightforward about what he needs from his team (including counsel).’

Work highlights

  • Successfully represented six importers of mobility scooters in group litigation against HMRC concerning the proper classification of these goods.
  • Represented 715 individuals and 29 LLPs in proceedings before the First-tier Tribunal and Upper Tribunal in appeals against tax demands by HMRC totalling £1.1bn.
  • Brought a judicial review against HMRC on behalf of 260 individuals who were members of the Eclipse tax schemes in connection with Accelerated Payment Notice and Follower Notices amounting to approx. £100m at stake.

Hogan Lovells International LLP

Hogan Lovells International LLP displays extensive tax litigation and investigations experience, particularly in cases that involve HMRC enquiries. The firm advises a range of US groups in the real estate, insurance and technology sectors. Key areas of focus for the practice include corporation tax, VAT, customs duty, excise duties, personal tax and stamp duties. Rupert Shiers leads the UK and European tax litigation practice.

Practice head(s):

Rupert Shiers

Other key lawyers:

Katharine Crossman; Katie Price; Suzanne Hill

Work highlights

  • Advised Pfizer on European Court of Justice litigation, overturning a Commission Regulation on customs duty classification.
  • Advised Ball Corporation on First-tier Tribunal litigation, overturning a discovery assessment using two novel arguments.
  • Acted for Eynsham Cricket club in Court of Appeal litigation, addressing zero-rating, charities law, and fundamental points of statutory interpretation.

Macfarlanes LLP

Macfarlanes LLP's tax team has 'great technical expertise' and 'deep knowledge' of tax investigations and litigation, HMRC enquiries and audits. The team represents clients before tax tribunals and civil courts in relation to a wide variety of direct and indirect tax disputes. Another area of focus includes advising high-net worth individuals on domicile and residence enquiries. The practice is led by Gideon Sanitt who has a 'great combination of brains, responsiveness and client awareness'. Senior solicitor advocate Ben Webster and senior counsel Joanna Constantis are also noted.

Practice head(s):

Gideon Sanitt

Other key lawyers:

Ben Webster; Joanna Constantis; Jackelyn West; Leyla Garahan; James Drake-Linney

Testimonials

This firm is a class act and clearly on top of its game.’

Gideon Sanitt – He is very able and easy to deal with . A great combination of brains, responsiveness and client awareness.’

Gideon Sanitt – stand out partner, fully understanding client perspective and brief, commercial.’

Excellent service and great technical expertise.’

Deep knowledge of relevant legislation and HMRC practice and approach. Up to date and relevant information on current topics and case law.’

Work highlights

  • Successfully acted for investors in 2 Enterprise Zone developments (concerning data-centres) in consolidated Judicial Review and Tax Appeal proceedings before the Upper Tribunal.
  • Successfully defended Royal Mail in a preliminary issues hearing relating to group litigation brought against it by more than 300 claimants with respect to VAT claims dating back to the 1970s.

PwC LLP

PwC LLP has a broad tax practice comprising of solicitors, barristers, accredited mediators, CTAs and accountants. The team's core strengths are handling direct, indirect, employment and environmental tax litigation, tax investigations and transfer pricing. The team represents a wide variety of clients in financial services, manufacturing, pharmaceutical, healthcare, education, retail, local government and pensions. Mark Whitehouse heads the direct tax disputes practice and has particular experience in group litigation orders, tax planning and corporate tax appeals. David Anderson leads the indirect tax disputes work and specialises in VAT. Legal disputes practice head and barrister Stephen Morse specialises in tax litigation and disputes resolution. Peter Johnson, a chartered accountant and chartered tax advisor is also noted.

Practice head(s):

Stephen Morse; Mark Whitehouse; David Anderson

Other key lawyers:

Peter Johnson; Jayne Harrold

Key clients

General Electric

St George’s University

Group Litigation (20 clients )

Target Group

Orange Spain (& Others)

The Wellcome Trust

Reckitt Benckiser Group plc

Rank Group plc

United Biscuits (Pension Trustees) Ltd

Healthspan Ltd

Wells Fargo

Worldpay

Phoenix Group

Royal Mail

General Electric Pension Fund

Global University Systems

Dollar Financial

Lebara

Virgin Media

Procter & Gamble

Aggregate Industries

Work highlights

  • Represented St George’s University in its successful First-tier Tribunal appeal concerning the proper scope of the VAT exemption for supplies of education, which was the first time a UK court or tribunal has considered the “complex supply” of education provided in both UK and overseas locations.
  • Representing Target Group Ltd in relation to its appeal before the Court of Appeal. The appeal concerns the scope of the VAT exemption for payments and transfers as matter of UK law.
  • Representing GE in the High Court, Tax Tribunal and Court of Appeal in relation to HMRC’s decision to resile from a statutory clearance in relation to a finance and holding structure used by the group.

Quinn Emanuel Urquhart & Sullivan, LLP

Quinn Emanuel Urquhart & Sullivan, LLP is a 'go-to practice for big-ticket tax disputes'. The team has 'enormous experience' handling multijurisdictional tax disputes and bilateral investment treaty arbitrations for clients in a range of industries, including mining, telecoms, oil and gas. The practice also displays expertise handling tax issues for sports clubs and ultra-high net worth individuals. Practice head Liesl Fichardt is a 'superb tax lawyer' with extensive experience handling complex international tax investigations and disputes. Epaminontas Triantafilou focuses on international arbitration and of counsel Karabeth Ovenden represents high-net worth individuals and multinational corporations in complex tax disputes.

Practice head(s):

Liesl Fichardt

Other key lawyers:

Epaminontas Triantafilou; Anthony Sinclair; Karabeth Ovenden; Chintan Chandrachud; Michael Mabbett

Testimonials

The team at Quinn Emmanuel has enormous experience of handling cross border tax litigation. Liesl Fichardt in particular knows how to manage litigation of this kind.’

Liesl Fichardt is a superb tax lawyer, for whom there are not enough superlatives. Technically brilliant in the principles and details of domestic and international taxation law, she has a fantastic strategic nous and great skill and experience in dealing with tax authorities.

Huge experience in dealing with domestic and international tax issues, negotiating with tax authorities and handling disputes through domestic and international tribunals and all levels of court up to the Supreme Court. A go-to practice for big-ticket tax disputes.’

Liesl Fichardt is undoubtedly one of the outstanding tax litigators in the UK. She is determined and shows the soundest judgement is difficult situations.’

The technical skills married with the people skills is what makes the difference. Tax disputes can be stressful and the professionals at Quinn Emanuel are able to provide such professional and incisive work in a most personable and understandable way.’

Key clients

Barrick Gold Corporation

Shanta Gold

Global Media

Radiocentre Limited

Millicom

Essar Group

Barrick Gold Corporation Group and international subsidiaries (Tax and Regulatory)

Anglo Gold Ashanti

Alvarez & Marsal as Joint Administrators to NMC Healthcare LTD (in administration) and the other 35 NMC group companies in administration

TrustCo Holding Ltd

Work highlights

  • Advised Barrick Gold Corporation on disputes involving tax residency, transfer pricing, foreign exchange and customs issues, with many of these cases currently at the highest judicial tribunal of the relevant state, including at the Court of Appeal of Tanzania.
  • Advised Radiocentre Limited on the tax status of all radio presenters, given the new IR35 regime.

RPC

RPC has an 'exceptional' tax disputes team with a broad client offering that covers contentious civil direct and indirect tax (including VAT and customs and excise duty) and criminal investigation and defence work. The team has been increasingly advising clients on public law and judicial review issues against HMRC. Practice head Adam Craggs has extensive experience advising on direct and indirect tax dispute resolution, and is also an accredited mediator. Robert Waterson has a broad direct and indirect tax litigation practice and frequently assists clients with cases involving issues of public and EU law. Michelle Sloane specialises in VAT, and customs and excise duty disputes. In 2020, Sloane was promoted to partner, while senior associate Harry Smith joined the team from KPMG Law in the United Kingdom.

Practice head(s):

Adam Craggs

Other key lawyers:

Robert Waterson; Michelle Sloane; Rebekka Sandwell; Constantine Christof; Alice Kempi; Harry Smith

Testimonials

RPC LLP has a particularly strong presence in group litigation of tax cases. This is largely down to the personal knowledge and capabilities of partner Adam Craggs ably supported by his talented support team.’

Partner Adam Craggs and Associate Rebekka Sandwell – they are experienced, responsive and good to work with.’

What sets RPC apart from the competition is that they have real empathy with their clients. You really feel that they are on your side – they listen to your concerns, advise accordingly and expertly manage expectations. They always respond quickly which builds trust and reassurance in what they do and how they do it.’

Adam Craggs (partner) and Constantine (Costa) Christofi (senior associate) are an exceptional team. They do genuinely work together for the benefit of clients.’

Key clients

TSB Plc

Frasers Group PLC

Universal Cycles Ltd

Metropolitan International Schools Ltd

Emblin & Reid

Newcastle United Football Club

Steven Hoey

Work highlights

  • Representing TSB in relation to a VAT dispute regarding a transitional services agreement following the bank’s split with Lloyds.
  • Representing Frasers Group in a high profile cross-border tax enquiry involving the Belgian State.
  • Representing Universal Cycles in a high-value dispute regarding Anti-Dumping Duty, Customs Duty and VAT.

Bird & Bird LLP

Bird & Bird LLP's tax team is 'extremely experienced' in handling criminal defence, tax litigation and investigations work. Practice head Andy Brown specialises in alternative dispute resolution and cross-border tax disputes. Brown is praised by clients as 'exceptionally personable and pragmatic'. Legal director Nicola O’Connor focuses on tax investigations, particularly white-collar criminal defence work. 'Very diligent and knowledgable' senior associate Jack Prytherch is also noted.

Practice head(s):

Andy Brown

Other key lawyers:

Nicola O’Connor; Jack Prytherch

Testimonials

Exceptionally capable and versatile team, that will fight the corner of their clients and stand their ground against HMRC.’

A strong team with good strategic leadership and very hard working, bright associates focussed on delivering practical, cost effective outcomes for clients.’

Extremely experienced in cases involving tax investigations and defending revenue prosecutions. Very knowledgeable, good judgment and tactician, a calming influence with clients.’

Andy Brown- exceptionally personable and pragmatic partner.’

Jack Prythetch- brilliant up and coming associate, very diligent and knowledgable.’

Key clients

B&M Retail

Zarathustra Jal Amrolia and Isidora Ranjit-Singh

Work highlights

  • Advised a US-headquartered multinational corporation on the disclosure of multi-million pound VAT and corporation tax errors relating to its operations in the UK.
  • Advised an accountancy and payroll firm under criminal investigation on suspicion of multi-million pound tax fraud offences.
  • Advised a leading sporting goods retailer on its judicial review, tribunal appeals and other legal challenges against HMRC decisions to demand security for customs duty and import VAT.

Ernst & Young LLP

Ernst & Young LLP's tax disputes practice consists of solicitors and forensic accountants, allowing the firm to offer in-depth expertise. The team advises clients on disputes that involve VAT, landfill tax, income and corporation tax and EU disputes. Seasoned litigator Boaz Goren heads up the direct tax litigation practice. Mitchell Moss leads the indirect tax disputes team and has extensive experience of advising clients on dispute resolution in relation to VAT and other indirect taxes. Clients describe the team as 'practical, pragmatic and great to work with'.

Practice head(s):

Boaz Goren; Mitchell Moss

Other key lawyers:

Julian Balson; Richard Doran

Testimonials

Real time access to tax technical partners keeps tax litigation on track.’

EY has a tough, skilled team, which can navigate a litigant through the technicalities of tax and the skirmishing, which occurs too often these days in relation to procedure in a tax appeal.’

Boaz Goren combines experience with novelty in his approach to the issues which arise in tax litigation, coupled with the will to fight.’

Excellent team, good commercial and technical knowledge. Practical, pragmatic and great to work with.’

Key clients

Alasdair Locke

Biffa Waste Services Limited

Dolphin Drilling Limited

Work highlights

  • Represented Mr Alasdair Locke at the High Court and Court of Appeal on a challenge to follower notices and accelerated payment notices (FNs and APNs) issued by HMRC, brought by way of an application for judicial review.
  • Advised 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 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 covers a broad range of areas, including complex VAT issues, customs duties, loan relationship, international tax and more. Practice head Giles Salmond has extensive tax litigation experience that 'sets him apart' from others. Salmond has particular expertise advising clients on EU law aspects of UK tax law. Senior associate Kunal Nathwani is also noted and has a broad international tax disputes and investigations practice.

Practice head(s):

Giles Salmond; David Jervis

Other key lawyers:

Kunal Nathwani; Matt Cummings; Edward Griffiths

Testimonials

Relevant technical knowledge, adaptable to specific and difficult circumstances.’

Giles Salmond – very thorough and a thought leader.’

Ed Griffiths – Well-informed, view and advice covers all different scenarios (thinks widely).’

Giles and the team deal with all aspects of tax litigation and settlement matters in a practical and efficient manner and are always able to suggest sensible options to clients who are navigating what can be a daunting, complex and multi-faceted process.’

Giles’ experience in leading high profile tax disputes over the years sets him apart from the competition.’

Key clients

PriceWaterhouseCoopers LLP

Aozora GMAC Investments Limited

KPMG Law in the United Kingdom

KPMG Law in the United Kingdom has 'impressive' breadth of knowledge in relation to tax law and has a team of solicitors, solicitor advocates, barristers and ex-HMRC professionals. Amanda Brown heads the tax disputes and investigations practice and Matthew Fleming leads the indirect tax disputes practice. Angela Savin has a broad tax practice that covers diverted profits tax, permanent establishment and residence disputes and double tax treaty disputes. Director Colette van Zyl is also noted and is 'very knowledgeable', particularly in relation to VAT.

Practice head(s):

Amanda Brown

Other key lawyers:

Matthew Fleming; Angela Savin; Colette van Zyl

Testimonials

The particularly impressive things about the team are their breadth of knowledge and the degree of their specialisation in all areas of tax, in particular in VAT which is where I’ve encountered them most often. They are extremely proactive in identifying areas where clients might be able to improve their VAT position and in pursuing those possibilities to work out the best solution that their clients can get.’

Colette van Zyl is a very knowledgeable, proactive solicitor, who has an excellent understanding of VAT law. What I particularly value is her imaginative approach to finding solutions to problems, and her perseverance in getting to the bottom of all sorts of individual points that she is constantly on the look out for in her cases.’

Expertise in missing trader fraud investigation and knowledge of HMRC.’

Key clients

Cape Industrial Services Limited

Devon Waste Management

DHL

Euromoney plc

GLL BVK

HSBC Bank plc

Intercontinental Hotels

Jupiter Asset Management plc

Glint Financial Services

Chelmsford City and Midlothian Councils

Lloyds Banking Group

Poundland Limited

Robert Wiseman and Sons Limited

RPS

Thyssenkrupp Materials (UK)

United Grand Lodge of England

Volkswagen Financial Services (UK)

William Hill plc

Work highlights

  • Representing HSBC in a dispute with HMRC about whether UK branches of non-UK incorporated global service centre entities are entitled to be members of the bank’s UK VAT group.
  • Acting for Martin Fowler in the first ever virtual Supreme Court hearing, in a case wherein the result is now the leading authority on statutory deeming provisions.
  • Representing Jupiter Asset Management plc in a dispute with HMRC on a novel point of law relating to the valuation (for VAT purposes) of management services from a holding company to a group of subsidiaries.

Mishcon de Reya LLP

Mishcon de Reya LLP has 'excellent strength in depth', with a team of 'impressive practitioners' that advises on indirect and direct tax, civil and criminal investigations for corporates and private clients. Leslie Allen, who heads up the tax disputes and investigations practice, has extensive experience of representing clients before the Tax Tribunal and Supreme Court. Robert Hartley, who is 'very knowledgeable' and 'pragmatic', advises on both direct and indirect tax. Paul Noble and recently promoted legal director Waqar Shah are also recommended.

Practice head(s):

Leslie Allen

Other key lawyers:

Robert Hartley; Paul Noble; Dario Garcia; Waqar Shah

Testimonials

Mishcon are right at the top of the tree in the tax world. The team has excellent strength in depth, with an array of impressive practitioners. They are capable of (and do) run the most complex cases. They combine fantastic client service with a comprehensive legal approach.’

Les Allen is one of the stand out practitioners in this area. He is very easy to work with, and combines good judgment with pragmatic advice. He is supported by two fantastic associates, Waqar Shah and Richard Harvey. They are stars of the future in this practice area and are already showing their impressive legal and client skills.’

Robert Hartley presented as very knowledgeable but delivered pragmatic advice which was appropriately tailored for internal client stakeholders, including directors.’

Key clients

Royal Mail Group Litigation

Zipvit

Iceland Foods Limited

Europcar Group UK Limited

Anna Cook

Norton Rose Fulbright

At Norton Rose Fulbright,  Dominic Stuttaford heads up the tax practice for Europe, Middle East and Asia and Brazil. Stuttaford is 'absolutely brilliant', 'tactically astute' and an experienced tax litigator. The team represents clients in tax authority investigations and a broad range of tax disputes involving the major UK courts and tribunals, as well as the European Court of Justice. Contentious tax lawyer Chris Bates advises on HMRC investigations, risk reviews and tax governance and compliance matters. Michael Alliston is also noted.

Practice head(s):

Dominic Stuttaford

Other key lawyers:

Chris Bates; Matthew Hodkin; Ruth Cowley; Michael Alliston

Testimonials

Outstanding.’

Dominic Stuttaford is absolutely brilliant! He knows tax law and practice like no-one else. He’s stunningly clever, unbelievably knowledgeable, a terrific lawyer, tactically astute and a delight to work with.’

Key clients

BMW

HSBC

Lloyds Banking Group

Takeda (formerly Shire)

Royal Bank of Canada

Work highlights

  • Acting for Takeda (formerly Shire) in a restitution claim in the Stamp Taxes Group Litigation Order relating to Stamp Duty Reserve Tax.
  • Acting for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.

Simmons & Simmons

Simmons & Simmons has a broad tax disputes practice and handles the full range of civil and criminal tax litigation and investigations. The team has significant expertise in the financial services regulation space and advises on mis-selling of tax schemes, Financial Services Authority investigations, international tax disputes and state aid. Nick Skerrett leads the team, which includes Monique van Herksen, Darren Oswick and of counsel Heather Rowlands.

Practice head(s):

Nick Skerrett

Other key lawyers:

Darren Oswick; Monique van Herksen; Heather Rowlands; Tomoko Ikawa

Stewarts Law LLP

Stewarts Law LLP is a 'technically excellent and innovative' firm that only handles litigation. The practice is active in four areas of tax disputes: direct tax litigation, indirect tax litigation, commercial tax litigation and tax investigations. Practice head David Pickstone, who founded the department, specialises in direct tax, environmental tax and commercial tax litigation. Leeds-based Lee Ellis, who leads the direct tax litigation offering, advises clients on cases against HMRC. 'Stand out VAT partner' Victor Cramer leads the indirect tax offering; clients describe him as 'passionate' and a 'creative thinker'.

Practice head(s):

David Pickstone

Other key lawyers:

Lee Ellis; James le Gallais; Victor Cramer; Sarah Stenton; Lisa Vanderheide

Testimonials

Really technically excellent and innovative. Their smaller size means that they can be nimble and flexible and deliver for the client without using inappropriately high levels of unnecessary resource.’

Victor Cramer is a stand-out VAT partner – really technically minded and very passionate about the subject. He is a creative thinker and really a joy to work with. Lisa Vanderheide and Sarah Stenton are also stars in the firm’s direct tax field. Both are real self-starters and have a lot of initiative and expertise.’

Forward thinking and innovative. Very good at thinking on their feet. Friendly and reliable.’

Strong technical knowledge combined with disputes experience – particularly Victor Cramer.’

Key clients

Tayto Group Limited

FCC Recycling UK Limited

Singleton Birch Limited

John Jaekel

The Claims Guys Ltd

Ingenious Litigation

Eclipse Group Action

Scotts Atlantic Group Action

Work highlights

  • Representing Tayto Group limited before the Tax Tribunal on an appeal concerning deductions of goodwill being denied by the HMRC.
  • Acting for FCC Recycling Limited and Singleton Birch Limited on appeal to Tax Tribunal in respect of c.£10m assessment to Landfill Tax issued by HMRC regarding relevant waste.
  • Advising The Claims Guys Ltd on an opportunity to reclaim VAT accounted for to HMRC.

Weil, Gotshal & Manges (London) LLP

At Weil, Gotshal & Manges (London) LLP, the team handles a broad spectrum of high-profile tax disputes and is notably active in litigation against the tax authorities and insurance-related mandates. The group also works closely with the firm's global network on cross-border issues and has significant experience before the Court of Appeal, the Supreme Court and the European Court of Justice. Key practitioners include Oliver Walker, Jenny Doak, Jamie Maples and newly promoted partner Christopher Marks. Aron Joy and counsel Hayley Lund also contribute to the practice.

Practice head(s):

Oliver Walker; Jenny Doak; Jamie Maples; Christopher Marks

Other key lawyers:

Aron Joy; Hayley Lund

Key clients

Littlewoods Group

Joint Special Administrators of MF Global UK

Advent International

Providence Equity Partners

Work highlights

  • Advising the joint special administrators of MF Global UK on the administration of MF Global UK under the UK’s Special Administration Regime.

Bark&co

Bark&co's team advises on a broad range of civil tax litigation and investigations, as well as high-value criminal tax fraud cases. Founding partner Giles Bark-Jones advises on VAT fraud cases and challenges to HMRC assessments. Peter Finbow, who is 'dedication personified', also has a strong VAT fraud practice.

Practice head(s):

Giles Bark-Jones

Other key lawyers:

Peter Finbow

Testimonials

The dedication of the Bark & Co team to each and every case is unrivalled. They commit the same energy, expertise, and effort to each client, however large, small, complex, or straightforward the case.’

Peter Finbow is dedication personified. He leaves no stone unturned. He has the eye of a hawk for detail, and is a formidable force to have on your team. I have worked with Peter for many, many years, on cases big and small, and he continues to impress.

Work highlights

  • Represented Dominic Chappell in relation to his prosecution for various counts of tax fraud arising out of his takeover of BHS from Sir Philip Green.
  • Acting for an individual in investigations by the National Crime Agency and SKAT (the Danish tax authority) into fraud and money-laundering activities worth over £1.5bn committed against the tax authorities in a number of countries, predominantly the UK, Denmark, the US and Belgium.
  • Representing a large, well-established alcohol wholesaler that HMRC decided was not ‘fit and proper’ for the purposes of the Alcohol Wholesalers Registration Scheme.

BCL Solicitors LLP

BCL Solicitors LLP has a strong specialism in tax fraud cases and it acts for a broad range of clients in the financial services and legal sectors, among others. The team is particularly knowledgeable about technical tax matters, including those where there is an interplay between unlawful tax evasion and legitimate tax planning. Harry Travers leads the team, which includes founding partner Ian Burton and John Binns.

Practice head(s):

Harry Travers

Other key lawyers:

Ian Burton; John Binns

Testimonials

BCL Solicitors LLP is a great firm with a great reputation, and I wouldn’t hesitate to recommend them.’

Harry Travers has an excellent analytical mind, which sets him apart from many others in this area.’

One of the oldest specialist boutiques with strength in depth across the partner and associate rosters. Has an excellent track record in acting in the most high profile criminal tax cases. One of the few firms that combines in-depth tax experience with top-notch criminal expertise.’

The BCL team is thorough and assimilates complex data and information well.

Harry Travers – very easy to work with, excellent communicator and very smart.’

John Binns – partner – has really excellent communication and client management skills. Also great legal skills and knowledge of the issues.

Harry Travers is a ‘thinker’ who looks at all potential avenues to secure the desired result for his client.

Charles Russell Speechlys LLP

Charles Russell Speechlys LLP advises on HMRC enquiries, investigations and tax litigation, with particular expertise advising on private client tax litigation. The team is led by recently promoted partner Hugh Gunson, who advises on direct and indirect taxes and covers income tax, CGT, inheritance tax, SDLT, corporation tax and VAT. According to a client, Gunson is a ‘rising star‘.

Practice head(s):

Hugh Gunson

Testimonials

The CRS Private Client Tax Litigation and Investigations practice are at the cutting edge of private client litigation. Their team combines technical knowledge with litigation judgment and always delivers for its clients.’

Hugh Gunson is the rising star of the UK private client tax litigation market. His background at the Bar combined with his technical tax knowledge gives him a real market edge.’

The team has got strength in breadth and depth and offer dispassionate, balanced and detailed advice which always serves the client’s interest in the long run.’

Hugh Gunson is likely to go far – effective, polished but ultimately a real lawyer’s lawyer when it comes to the detail.’

Work highlights

  • Acted for Nicola Mackay, the claimant in an application (and subsequent appeal) to the High Court to set aside her appointment as trustee of a trust on one of a number of grounds, including undue influence, capacity, mistake and non est factum.
  • Advised an offshore trust company in relation to a very complex and unusual tax issue and a related professional negligence claim against a law firm.
  • Advised a high net worth US individual on a long-running HMRC enquiry into her domicile status.

Kingsley Napley LLP

Kingsley Napley LLP specialises in representing high-net worth individuals and professionals who are involved in tax investigations by HMRC's Fraud Investigation Service. One of the names to note at the firm is David Sleight, who has an 'impressive' tax fraud and financial crime practice. He co-heads the practice with Louise Hodges, who advises on tax evasion cases. Ed Smyth, who is described as 'clever and innovative', handles a range of white-collar crime matters.

Practice head(s):

Louise Hodges; David Sleight

Other key lawyers:

Ed Smyth

Testimonials

Kingsley Napley’s tax litigation and investigations team are unique in their combination of cutting edge experience, for example in cum ex investigations, with real world knowledge of how to avoid, or fight and win criminal litigation.’

David Sleight has quietly been building one of the most impressive contested tax practices in London. His clients include hedge funds and big four partners. He is second to none at avoiding prosecution, but if that’s not possible he has the most impressive ability to spot the points that will win. Bright and canny.’

Ed Smyth is a clever and innovative lawyer. Ed is personable as well as being a fighter.’

Kingsley Napley are a well known firm in the financial crime field. Their work on HMRC investigations compliments their leading work in this field.’

Louise Hodges is a wise and experienced lawyer who is unflappable in a crisis.’

Kuit Steinart Levy LLP

Kuit Steinart Levy LLP undertakes a wide ambit of contentious tax work for clients, including tax scheme investigations, furlough fraud cases, criminal tax investigations and prosecutions. Team head Robert Levy represents a number of offshore banks in complex tax investigations. Paul Bricknell is recommended for tax disclosure work and investigations that concern false invoicing, cryptocurrency gain, property income and offshore structures.

Practice head(s):

Robert Levy

Other key lawyers:

Paul Bricknell

Testimonials

Open approach, collaborative and very experienced in financial and regulatory matters including bribery and corruption, money laundering, tax fraud and corporate/individual compliance.’

Robert Levy is a joy to work with, great experience, strong interpersonal skills and adopts a collaborative and inclusive approach to clients and intermediaries.’

Practice is unique in offering client friendly boutique style service. Professional approach and instruct counsel clearly and comprehensibly. Always available to discuss cases.’

Robert Levy and Paul Bricknell establish a strong rapport with clients and provide insightful, commercial advice. They have been particularly quick to adapt to new ways of working over the last year or so in response to the challenges of COVID-19.’

Osborne Clarke LLP

Osborne Clarke LLP stands out advising clients on tax disputes in the technology and financial services sectors, with a significant portion of its work having an international element. In addition, its team demonstrates strong capabilities in tax disputes connected with the off payroll/flexible workforce sector. Practice head Ian Hyde is a part time Tax Tribunal judge and qualified mediator. Associate director Matthew Greene is also recommended.

Practice head(s):

Ian Hyde

Other key lawyers:

Matthew Greene; Frances Lewis

Key clients

UBS AG

Domino’s Pizza Group PLC

Npower

Work highlights

  • Acting for an international web hosting platform group in relation to exchange of information provisions between the UK and India under the OECD Multilateral Convention on Mutual Administrative Assistance in tax matters, and on cross-border tax debt enforcement.
  • Representing a free to air digital TV channel in an appeal to the Tax Tribunal and mediation with HMRC following HMRC’s investigation into the historic VAT recovery and partial exemption position.

Peters & Peters Solicitors LLP

Peters & Peters Solicitors LLP is a 'go-to firm' for HMRC investigations, VAT and tax evasion cases. Practice head Neil Swift specialises in criminal tax fraud and civil cases, particularly matters involving VAT fraud, attendant money laundering and tax evasion. Swift is 'a talented solicitor' and 'a joy to work with'.

Practice head(s):

Neil Swift

Other key lawyers:

Maria Cronin; Rachel Cook

Testimonials

One of the real ‘go to’ firm firms for those who are facing inquiries by HMRC. Their record of successfully representing individuals speaks for itself. They are approachable, sensible, helpful and collegiate in their approach.’

I have worked most recently with Neil Swift who knows innately how to best represent an individual in a revenue investigation and whose manner is well-judged and who is unfailingly polite and helpful but tough when he needs to be.’

Peters and Peters has a well-respected tax team and strength in depth.’

Neil Swift is a seasoned practitioner whose careful preparation and bold strategy gets great results in the cases we’ve worked on together.’

Work highlights

  • Representing a high-profile entrepreneur with business interests in online gambling, payroll services, and various property investments and was arrested in March 2015 as part of a joint HMRC and NCA investigation on suspicion of evading c.£25 m VAT through a complex corporate structure involving offshore companies.