Firms To Watch: Tax litigation and investigations

Collyer Bristow LLP‘s team is spearheaded by Tax Tribunal judge James Austen, who is a notable thought leader in tax matters.
Stephenson Harwood‘s tax disputes team, which has core strength in the private equity and funds sector, recruited Shofiq Miah from Joseph Hage Aaronson LLP in November 2022.

Tax litigation and investigations in London

Herbert Smith Freehills LLP

Herbert Smith Freehills LLP‘s contentious tax team works within the firm’s full-service offering and has expertise in the full range of tax disputes. The group is active on behalf of prominent domestic and multinational clients and is experienced in key areas such as tax fraud and negligence. Department head Nick Clayton is a solicitor advocate and CEDR-accredited mediator who acts for financial institutions, corporates, and UHNWIs. Clayton is highly experienced in international tax matters, with expertise in both investigations and disputes. Michael Hunt advises on tax disputes across a range of sectors, including banking, energy, real estate and technology, and has experience at the First-Tier Tribunal, Upper Tribunal, and Court of Appeal. Senior associate Dawen Gao is described as ‘exceptional’ by clients.

Responsables de la pratique:

Nick Clayton


Autres avocats clés:

Michael Hunt; Dawen Gao; Avi Haffner


Les références

‘The team at HSF have been very excellent throughout our dispute resolution process, working collaboratively with our business and guiding us through both dispute resolution and litigation.’

‘Michael Hunt is an excellent tax lawyer and very responsive to the needs of our business. He has guided us seamlessly throughout litigation.’

‘Very responsive and hands-on. Realistic and well-measured advice. Highly experienced in all manner of litigation. A pleasure to work with. Serve their clients extremely well.’

Principaux clients

Axiata


UBS


PacifiCorp


Orsted


Berkeley Group


Neptune Energy


Guardian Assurance Limited


ReAssure Limited


Principaux dossiers


Joseph Hage Aaronson LLP

Boutique contentious tax firm Joseph Hage Aaronson LLP is well known for its expertise in complex domestic and cross-border tax disputes, including litigation, arbitration, and investigations. The department is jointly led by founding partners Michael Anderson, a highly experienced litigator with a specialism in the taxation of cryptocurrencies, and Graham Aaronson KC, who has expertise in transfer pricing, oil and gas taxation, and EU law. Also key are Simon Whitehead, who has over 35 years’ litigation experience, Paul Farmer, who has a broad background in European and international tax law, and Iain MacWhannell, who acts for a diverse and high profile client base of individuals, businesses, and trusts. Solicitor and chartered tax advisor Helen McGhee and Daniel Margolin KC are further core team members.

Responsables de la pratique:

Graham Aaronson KC; Michael Anderson


Autres avocats clés:

Iain MacWhannell; Simon Whitehead; Paul Farmer; Daniel Margolin KC; Helen McGhee


Les références

‘JHA is the only significant sized law firm that focuses on tax litigation (as opposed to simply being a tax department in a multi-service firm). It can properly be said, then, that they are true tax litigation experts. They are therefore always in the running (and likely in the lead) for any major tax controversy work.’

‘Iain MacWhannell is a star individual. His attention to detail is remarkable, and he has a real feel for litigation tactics (and an uncanny ability to predict what HMRC’s next move will be). Daniel Margolin KC is a class act. Measured, considered and smooth.’

‘The key strengths are the bespoke service afforded to the client as well as the attention to detail. The team also deliver a fully connected end-to-end strategy which takes account of all the pitfalls of litigation.’

Principaux clients

British American Tobacco PLC


Marks & Spencer Group PLC


Prudential PLC


AXA PLC


Ford Motor Company (FCE Bank PLC)


EMI Group Limited (Universal Music Group)


GKN Aerospace Limited


Fidelity International


ABRDN PLC


Prudential PLC


Principaux dossiers


  • Advised 25 UK headquartered multinationals in their challenge to the UK’s dividend taxation scheme.
  • Represented over 18,000 companies in their appeals to the Tax Tribunal against assessments to VAT, National Insurance Contributions, and VAT de-registration.
  • Pursued Closure Notice Applications in the First-Tier Tribunal on behalf of a group of approximately 180 taxpayers who are seeking repayment of unlawfully levied tax on foreign portfolio dividend income.

Slaughter and May

The ‘gold standard in tax litigation’, Slaughter and May is prominent in the full scope of contentious tax, including transfer pricing, diverted profits tax, and tax residence matters. The ‘very strong’ team benefits from a deep relationship with HMRC, significantly aiding in dispute resolution. Richard Jeens, who is experienced in complex multi-jurisdictional disputes, co-leads the department alongside Dominic Robertson, whose practice includes EU tax state aid investigations as well as transfer pricing and DPT enquiries. Ewan Brown co-heads the global investigations group and acts in both litigation and regulatory investigations. Mike Lane advises domestic and international clients on a range of contentious matters. Sarah Osprey made partner in May 2023 and advises major multinational clients in a diverse range of tax matters. Steve Edge retired from the practice in May 2022.

Responsables de la pratique:

Richard Jeens; Dominic Robertson


Autres avocats clés:

Ewan Brown; Mike Lane; Sarah Osprey


Les références

‘The gold standard in tax litigation. They are unrivalled in their ability to litigate large and complex points.’

‘Dominic Robertson is set to be the leader of his generation in the tax field. Huge knowledge and a great practical sense in the context of litigation.

‘Richard Jeens is completely reliable and always delivers excellent service. A joy to work with. Mike Lane is one of the best tax technical minds around.’

Principaux clients

BlueCrest Capital Management


GE


Mercuria Energy Europe Trading


Vitol


Principaux dossiers


  • Advised the Vitol group in relation to an ongoing transfer pricing and diverted profits tax (DPT) dispute with HMRC.
  • Advised BlueCrest, a leading hedge fund, on several matters relating to challenges to the UK tax treatment of its management incentivisation arrangements put in place by BlueCrest to incentivise and retain top personnel.
  • Advised GE, a large US multinational, on the allocation of taxing rights over a UK-US dual resident company.

Allen & Overy LLP

Allen & Overy LLP's large team works alongside the firm's non-contentious offering, and provides comprehensive support in all areas of tax disputes, including pre-litigation advice, negotiations with HMRC, and tax investigations. Chris Harrison co-leads the department alongside Charles Yorke, who regularly acts for financial institutions, major oil companies, and infrastructure groups. Senior partner Lydia Challen advises on supply chain finance, and regularly consults with HMRC on the development of tax legislation. Eve Giles is a key contact for financial crime investigations.

Responsables de la pratique:

Chris Harrison; Charles Yorke


Autres avocats clés:

Eve Giles; Lydia Challen


Les références

‘They are a highly professional outfit with deep expertise in tax.’

‘The individuals are very bright and very pleasant to work with. I have been particularly impressed with Charles Yorke.’

Principaux clients

Investec Bank plc


Lloyds Banking Group


Principaux dossiers


  • 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.
  • Advised clients on various cases in relation to both civil and criminal elements of diverted profits tax and transfer-pricing investigations.

Ashurst

Ashurst‘s disputes practice is active at all levels of the Tax Courts, including the Supreme Court and The Court of Justice of the European Union. The group represents numerous prominent clients, including both public and private groups. Team lead Nicholas Gardner covers both direct and indirect tax litigation, and is described by clients as ‘a deep thinker with unparalleled analytical ability.Paul Miller has expertise in the financial services industry. Senior associate Sara Mardell has experience in VAT and national insurance disputes, in addition to judicial review claims.

Responsables de la pratique:

Nicholas Gardner


Autres avocats clés:

Sara Mardell; Paul Miller


Les références

‘The team are very well-informed/knowledgeable and appear to work well together. It is clear that they have good communication between them and this makes their delivery efficient and relevant.’

‘Nicholas Gardner – a deep thinker with unparalleled analytical ability. Sara Mardell – currently a senior associate, but destined to be one of the most notable (and formidable) tax lawyers in the City. If you are litigating against HMRC, you want Sara in your team.’

‘Paul Miller is an excellent communicator and has a very sound judgment about litigation and prospects. Very good with clients. He also knows a lot about corporation tax loan relationships and has a very sound grasp of the law and a practical outlook.’

Principaux clients

Imperial Brands


Odfjell Drilling (UK) Limited (ODUK)


Balfour Beatty


Hastings Insurance Services Limited


Roadchef


Nacional Financiera SNC – London Branch


Mapeley STEPS


Principaux dossiers


  • Advised Imperial Brands on its application for annulment of the EU CFC decision.
  • Advised Wood Group on a FTT appeal concerning national insurance contributions dispute relating to offshore operation and maintenance services.
  • Advised Odfjell Drilling on FTT and judicial review appeals concerning national insurance contributions relating to offshore drilling services.

Baker McKenzie

Baker McKenzie‘s multidisciplinary team of lawyers, economists, and accountants supports clients through the development of complex multijurisdictional disputes and is regarded as ‘proactive in looking for solutions.’ Jointly leading the team are Jessica Eden, David Jamieson, and Nigel Dolman. Eden leads on corporate tax disputes, and is a CEDR accredited mediator, while Jamieson handles VAT disputes, and Dolman spearheads transfer pricing matters. Also key are Patrick O’Gara, who specialises in the digital, consumer goods, and pharma sectors, and Jukka Karjalainen, who co-leads the transfer pricing practice.

Responsables de la pratique:

David Jamieson; Jessica Eden; Nigel Dolman


Autres avocats clés:

Patrick O’Gara; Jukka Karjalainen


Les références

‘Excellent technical skills, proactive in looking for solutions. Knowledgeable about my industry and company.’

‘We receive a great service and everyone is able to react quickly to requests for support or enquiries.’

Principaux clients

Accenture


Baker Hughes


Core Media


Electronic Arts


European Tyre Enterprise Limited


Hutchison 3G Limited


Marriott


MDU (Medical Defence Union Limited)


UK Power Network


Principaux dossiers


  • 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.

Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner‘s ‘great, experienced team’ acts for an international client list on a diverse range of matters, including both criminal and civil investigations and defence work. Global tax head Elizabeth Bradley co-leads the group alongside contentious tax specialist Kate Ison, whose experience covers VAT disputes, compliance issues, and corporate internal investigations. Alan Sinyor has expertise in the VAT area and advises on both contentious and non-contentious matters. Associate Wesley Grimm joined in July 2022 from Webber Wentzel.

Responsables de la pratique:

Elizabeth Bradley; Kate Ison


Autres avocats clés:

Alan Sinyor; Wesley Grimm


Les références

‘Great, experienced team that works very well together and always delivers well for clients.’

‘Kate Ison has a huge amount of experience in tax disputes, particularly employment tax and SDLT. Always friendly and super efficient.’

‘Very responsive, outstanding experience, great collaboration among BCLP’s team members.’

Principaux dossiers


Clifford Chance LLP

Clifford Chance LLP has notable strength in international and cross border tax investigations, which draws a client list which includes a range of leading banks. The group is jointly led by Chris Davies, who was formerly the firm’s Global Head of Tax, and David Harkness, who offers over 30 years of experience in the area. David Saleh advises high profile clients on tax disputes, tax compliance, and tax controversies and also has a special focus on real estate tax.

Responsables de la pratique:

Chris Davies; David Harkness


Autres avocats clés:

David Saleh; Nicola Hemsley


Principaux dossiers


  • Advised a leading international bank on a dispute with HMRC as to the VAT treatment of some of the bank’s intra-group service payments.
  • Advised a leading international investment bank during the early stages of a dispute with HMRC over its bank levy liability.
  • Advised a global insurer on a multi-million-pound tax liability.

DLA Piper

DLA Piper‘s team works alongside the firm’s international network to support clients facing audits and disputes across the globe. The department has experience at all levels of the UK courts. Team lead Jason Collins, who is perceived as ‘a leader in tax dispute resolution‘, has a practice which includes transfer pricing, double tax treaties, and diverted profits tax. Stuart Walsh has particular expertise in VAT matters, frequently working closely in this area with legal director Clara Boyd, who is ‘very knowledgeable and easy to communicate with.’ Senior associate Lauren Redhead is experienced in both direct and indirect tax disputes.

Responsables de la pratique:

Jason Collins


Autres avocats clés:

Lauren Redhead; Richard Woolich; Clara Boyd; Stuart Walsh


Les références

‘Clara Boyd is very knowledgeable and easy to communicate with.’

‘A thriving part of DLA Piper under the dynamic leadership of Jason Collins. They combine intellectual acumen, extensive industry experience with sound judgment as to what will work in Court.’

‘Jason Collins and Lauren Redhead are a powerful senior partner/senior associate duo who get to the heart of the issues very quickly. Very good at managing client’s expectations and keeping all the plates spinning.’

Principaux clients

NatWest Markets plc


JVM Equipment Limited


Mid Ulster District Council


CCLA Investment Management Limited


Principaux dossiers


  • Acted for Natwest Markets plc in a dispute arising from missing traders in its carbon credit supply chains defaulting on VAT due to HMRC.
  • Acted for JVM Equipment Limited in a dispute concerning the application of Transfer Pricing rules.
  • Acted for Mid Ulster District Council in challenging HMRC’s denial of reclaims of VAT wrongly accounted for on sports and leisure services

Fieldfisher

Fieldfisher‘s growing team of ‘excellent’ lawyers covers the full range of contentious tax, including tax disclosures, Tribunal litigation, judicial reviews, and professional negligence. The group is highly international, and contains multiple HMRC-trained practitioners. Team lead George Gillham, who is a former HMRC tax inspector, covers both tax enquiries and litigation. Derek Hill, who is head of the firm’s tax group, has a broad practice which covers both contentious and non-contentious matters. Barrister Philippe Freund has expertise in cross border matters and criminal tax. Matthew Sharp specialises in employment tax disputes. Associate and barrister Christopher Kientzler is a further name to note.

Responsables de la pratique:

George Gillham


Autres avocats clés:

Derek Hill; Philippe Freund; Matthew Sharp; Siobhan Gillespie; Christopher Kientzler


Les références

‘A strong and symbiotic relationship between the members of the team who specialise in tax investigations and dealing directly with the HMRC, on the one hand, and those who are able to handle related litigation with third parties.’

‘Matthew Sharp is an up-and-coming associate who will go far.’

‘George Gillham is a stand-out tax lawyer: hugely knowledgeable, wonderful client manner, and a strong strategic sense of how to resolve disputes.’

Principaux clients

Alternative Resolution Consultancy LLP and Eclipse Film Partners LLPs


L Rowland & Co (Retail) Limited (Phoenix Medical)


Exchequer Solutions Limited


Sunrise Medical Ltd, TGA Mobility Limited, Drive Devilbiss Healthcare Limited, Electric Mobility Euro Limited, Freerider Luggie Limited


Sunrise Medical B.V. & Sunrise Medical Logistics B.V.


Hoegh Capital Partners


Aramark Limited


Principaux dossiers


  • Advised Alternative Resolution Consultancy LLP and Eclipse Film Partners LLPs on obtaining a tax settlement opportunity for HMRC to settle the tax affairs of over 700 partners for around £100m, replacing a dry tax charge of £1.6bn.
  • Advised Hoegh Capital Partners on multiple disclosures to HMRC through the Worldwide Disclosure Facility and other channels and a professional negligence claim against former accountants and solicitors who acted for them, worth approximately £25m.
  • Advised Rowland & Co in relation to an appeal to the First-tier Tribunal against assessments to income tax and national insurance determinations in a dispute over the employment status of locum pharmacists worth approximately £60m.

KPMG Law

KPMG Law‘s ‘unmatched’ team of tax dispute specialists acts on cutting-edge work for high-profile clients such as HSBC, Lloyds, and the United Grand Lodge of England. Matthew Fleming, who is qualified in both the UK and New Zealand, leads on indirect tax disputes. Angela Savin heads the direct taxes disputes practice and has notable strength in advising taxpayers in main purpose tax disputes with HMRC. The ‘exceptional’ Amanda Brown KC advises and represents clients in a broad range of matters. Director Colette Van Zyl advises on all aspects of indirect tax litigation.

Responsables de la pratique:

Angela Savin; Matthew Fleming


Autres avocats clés:

Amanda Brown KC; Colette van Zyl; Lee Ellis


Les références

‘I think what makes this practice unique is the ability to leverage the depth and breadth of the KPMG firm. Outside of the legal professionals we were able to leverage accountants and tax specialists who were market leaders in the field that impacted us.’

‘Matthew Fleming was truly tremendous to work. What made Matthew stand out to me was his desire to understand our business and ensure that he was able to apply the law to our facts and circumstances. I truly trust Matthew.’

‘I particularly like the combination of a specialist tax legal team working alongside accounting tax specialists. That combination means they think about how the law translates to numbers and commercial risk.’

Principaux clients

Altrad Services Limited


Chelmsford City Council


DHL Air Ltd


Euromoney Institutional Investor plc


GAP Group Limited


Genesis Cancer Care Limited


Gloucestershire Hospitals NHS Foundation Trust


HSBC Bank plc


Knot Builders Ltd


Kopparberg


Lloyds Bank Plc


Midlothian Council


Pye Motors Limited


Robert Wiseman and Sons Limited


Sonder


Thyssenkrupp Materials (UK) Limited


United Grand Lodge of England


Principaux dossiers


  • Represented HSBC in a dispute with HMRC about whether UK branches of non-UK incorporated global service centre entities are entitled to be in HSBC’s VAT group.
  • Represented Euromoney in a dispute with HMRC regarding the corporation tax treatment of the disposal of its stake in a financial data publishing business to the Carlyle group.
  • Acted for Gloucestershire Hospitals NHS Foundation Trust on a ground-breaking and precedent-setting judicial review concerning the correct VAT treatment of NHS Contracted Out Services.

Macfarlanes LLP

One of the most professional and respected tax litigation teams in the market’, the Macfarlanes LLP team provides comprehensive support, with expertise in both direct and indirect tax disputes. Lead partner Gideon Sanitt has experience at all levels of the UK and European Courts and acts for both high-profile individuals and corporate clients. Sanitt is supported by senior counsel Ben Webster, who is a solicitor advocate with experience in disputes with HMRC, judicial review cases, and disputes between taxpayers. Senior associate Sophie Rhind joined the department from HMRC in 2021 and brings key expertise in judicial review matters.

Responsables de la pratique:

Gideon Sanitt


Autres avocats clés:

Sebastian Prichard Jones; Ben Webster; Sophie Rhind; Jackelyn West


Les références

‘The team has a deep knowledge of tax matters and a tactical approach to case management. They are very approachable and help us to manage matters in a way which is focused on results.’

‘Ben Webster and Gideon Sanitt have been excellent. Their depth of experience has served us well. I trust their judgement implicitly and feel that they are working with us at all times to get the best result for us.’

‘Their output is high quality and comprehensive. Unlike other advisers, their first draft advice needs little input: They’ve clearly grasped the factual position and fully applied the law to the facts to produce a note that is full and clear.’

Principaux clients

Royal Mail Group


Odey Asset Management


HFFX LLP


CDC Administration


Principaux dossiers


  • Advised Odey Asset Management and a number of its individual members on a dispute with HMRC regarding the tax impact of a historic incentivisation and retention mechanism for key partners.
  • Advised Royal Mail in the group litigation brought against it involving circa 300 claimants.
  • Advised HFFX LLP and a number of its individual members on a dispute with HMRC regarding its Capital Allocation Plan.

Pinsent Masons LLP

Pinsent Masons LLP fields a team with considerably broad tax expertise, with coverage of areas such as aggregates levy, landfill tax, and oil and gas taxation. Team lead Steven Porter, who works from Manchester, has a contentious practice which covers matters related to both direct and indirect tax. Andrew Sackey leads on tax fraud investigations work and prior to joining the firm was a Case Controller at the UK’s Serious Fraud Office. Jake Landman is highly experienced in tax litigation. Other core team members include legal director Ian Robotham and associate Sam Wardleworth.

Responsables de la pratique:

Steven Porter


Autres avocats clés:

Andrew Sackey; Jake Landman; Ian Robotham; Sam Wardleworth


Les références

‘The firm are technically very strong in the field. Their experience of handing complex disputes and how they are inter-related to other live cases before the Courts demonstrates a level of dynamic thinking that is highly valued.’

‘Jake Landman is an articulate professional, able to communicate rather nuanced and finely balanced points clearly to a non-legal audience.’

‘Pinsents demonstrated an exceptional knowledge of the legislation and understanding of the issues to be addressed and always managed to present their advice in a meaningful and understandable way, despite the complexities of the case.’

Principaux clients

BT Pension Scheme


Gala Film Partners LLP


Cantor Fitzgerald


Dalriada Trustees Limited


Centrica Overseas Holdings Limited (COHL)


Skatteforvaltningen


Principaux dossiers


  • Acted for the Danish Tax Authority on a large-scale alleged fraud against them, including on the proper extent of the longstanding Revenue Rule.
  • Acted for Centrica Overseas Holding Limited on a key corporation tax dispute regarding the deductibility of management expenses, with wide potential implications for corporate groups.
  • Acted for Dalriada Trustees Limited on the lead case on tax issues arising in the context of pension liberation with a large group of taxpayers.

PwC LLP

PwC LLP covers the full range of direct and indirect tax disputes, with expertise in investigations, litigation, and out-of-court ADR. Highly experienced partners Mark Whitehouse and David Anderson jointly lead the department. Whitehouse has particular expertise in matters of international taxation, including transfer pricing disputes and EU Group Litigation actions. Anderson specialises in indirect tax disputes, and is praised by clients for his ‘great technical ability’. Director Peter Johnson has key strength in disputes involving international corporate tax and financing structures.

Responsables de la pratique:

Mark Whitehouse; David Anderson


Autres avocats clés:

Peter Johnson; Victor Cramer


Les références

‘Expertise across a wide range of subjects – combining great technical ability with strategic thinking in the context of litigation.’

‘Mark Whitehouse has huge experience in large and complex cases and is able to navigate through the thickets of complexity to identify the pragmatic route forward.’

‘The team we dealt with was great, had a thorough knowledge of the situation based on past experience. The team was detail oriented and considered the situation from several different angles.’

Principaux clients

TalkTalk Telecom Limited


Target Group Limited


Hippodrome Casino Limited


Procter & Gamble International Operations SA


General Electric


Experian plc


Genus plc


Informa plc


Just Eat plc


Keller Group plc


Man Group Limited


Merlin Entertainments Limited


Royal Mail Group plc


Sensata Technologies Inc.


Smith & Nephew plc


Ultra Electronics Holdings plc


Principaux dossiers


  • Advised General Electric on the settlement of an alleged $1bn tax fraud claim brought by HMRC in relation to the anti-arbitrage and unallowable purpose rules.
  • Acted in a case brought by Target Group Limited, which is being appealed to the Supreme Court, relating to the extent to which VAT can be added to links within the chain of events that lead to the movement of money.
  • Acted in a VAT appeal brought by TalkTalk Telecom Limited against a VAT assessment made by HMRC in relation to prompt payment discounts.

Quinn Emanuel Urquhart & Sullivan, LLP

Quinn Emanuel Urquhart & Sullivan, LLP has core strengths in complex tax and financing disputes and has been seeing growth in private client, regulatory, and professional negligence matters. Team lead Liesl Fichardt is regarded as ‘a consummate litigator’ with a long record in tax, finance, and debt-related investigations and disputes. Epaminontas Triantafilou leads on tax arbitration matters and is experienced acting as arbitrator as well as counsel to both private corporations and sovereign governments. Associate Emily Au is lead contact for multiple HNWI and corporate clients.

Responsables de la pratique:

Liesl Fichardt


Autres avocats clés:

Epaminontas Triantafilou; Emily Au


Les références

‘A group of top quality tax lawyers steeped in tax litigation.’

‘Liesl Fichardt is a technically accomplished lawyer with great client hands. She has outstanding communication skills and deep experience in dealings with HMRC.’

‘This UK branch of an international practice with global reach benefits from the breadth of experience available to it and so has the capacity to innovate and so to invigorate potentially stale tactics.’

Principaux clients

Lockton Group Companies


Jane Street Group LLC


Barrick Gold Corporation Group


Anglo Gold Ashanti


Bauer Media


Sustainable Investment Enterprises Limited (SIE)


Saracens Ltd


Principaux dossiers


  • Advised Lockton Group Companies in a pending dispute against HMRC which is the second in a group of cases involving mixed membership rules and the lead case on specific issues which have never previously determined by the courts regarding LLP structures.

RPC

RPC offers a full-service tax disputes practice with expertise in the full range of areas, from dawn raids and criminal investigations to tax litigation and transfer pricing disputes. Department head Adam Craggs has over 30 years’ experience in direct and indirect tax disputes and is an accredited mediator. Robert Waterson‘s practice is focused on multijurisdictional disputes, including those involving issues of public and EU law. Michelle Sloane advises on both civil and criminal tax matters, with experience at the Court of Appeal and Supreme Court. Senior associate Harry Smith has broad sector expertise and advises on both domestic and international tax matters.

Responsables de la pratique:

Adam Craggs


Autres avocats clés:

Robert Waterson; Michelle Sloane; Harry Smith


Principaux clients

TSB


Frasers Group PLC


Universal Cycles


Metropolitan International Schools Ltd


Newcastle United Football Club


Clipperton & Lloyd


AML Tax (UK) Ltd


Principaux dossiers


  • 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.
  • Led on major litigation for Universal Cycles Limited concerning the application of additional duty following an investigation by the EU anti-fraud body, OLAF.

Simmons & Simmons

Simmons & Simmons‘ multidisciplinary team, which boasts ‘a wealth of experience and expertise’, acts for prominent corporate, institutional, and high net worth clients on a broad range of matters. The department includes a dedicated transfer pricing team. Global contentious tax head Nick Skerrett leads the department, and is described as ‘the expert in the field of VAT litigation.’ Monique van Herksen, who is based between London and Amsterdam, specialises in transfer pricing. Newly promoted partner Heather Rowlands has key expertise in indirect tax and environmental tax matters as well as judicial reviews.

Responsables de la pratique:

Nick Skerrett


Autres avocats clés:

Monique Van Herksen; Heather Rowlands


Les références

‘This is a really impressive team with detailed knowledge of tax law and a wealth of experience and expertise. The team is particularly effective at working with other teams (e.g. commercial dispute resolution) to form a multidisciplinary team that is bespoke to a particular client engagement.’

‘Nick Skerrett is first class. He has detailed knowledge of tax law and thinks outside the box for creative arguments and solutions. Heather Rowlands is a careful lawyer with a keen eye for detail.’

‘Nick Skerrett is constantly thinking outside the box, looking for solutions for his clients. Heather Rowlands of Counsel is incredibly diligent and has a fantastic grip on the detail of her cases.’

Principaux clients

Augean plc


Veolia


Fidelity


Halfords


Principaux dossiers


  • Acted for leading waste manager Augean plc on appeals against landfill tax assessments imposed by HMRC.
  • Represented two of the four parties to the Devon Waste Management litigation.

Bird & Bird LLP

Bird & Bird LLP advises clients on the full spectrum of contentious tax matters, including investigation projects, alternative dispute resolution, civil litigation, and criminal prosecutions. Team lead Andy Brown specialises in tax avoidance, evasion, and allegations of fraud. Senior associate Chris Young advises corporates and private clients in disputes related to money laundering. The department has seen recent growth at the associate level, with Jennifer Southern joining from HMRC in June 2022, and Caitriona Moran moving from William Fry LLP in September 2022.

Responsables de la pratique:

Andy Brown


Autres avocats clés:

Chris Young; Jennifer Southern; Caitriona Moran


Les références

‘A very hands on and practical team with good experience of internal investigations.’

‘Andy Brown has an excellent barometer for risk and a practical approach to internal investigations.’

‘This is a unique practice in my view, with considerable strengths which compare favourably with their industry competitors because the members of the team have significant experience in this field which they are able to draw upon to provide expert advice and representation.’

Principaux clients

B&M Retail


Kammac plc


W F & L Limited


Push Energy


CVR Global Offshore Limited


Principaux dossiers


  • 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 on 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.

Ernst & Young LLP

Ernst & Young LLP‘s tax team has developed a strong reputation for tax litigation, judicial review, and alternative dispute resolution proceedings with HMRC since its establishment in 2016. Boaz Goren, Mitchell Moss and Julian Balson co-lead. Goren, who made partner in 2021, has experience in tax litigation at all levels of the UK tax courts. Moss leads on indirect tax disputes and has over 20 years’ experience in the practice area. Balson has expertise in tax enquiries and investigations, including both civil and criminal matters. Directors Richard Doran and Elyse Waller are further core team members.

Responsables de la pratique:

Boaz Goren; Mitchell Moss; Julian Balson


Autres avocats clés:

Richard Doran; Elyse Waller


Les références

‘The EY tax dispute resolution team are extremely collaborative, take a commercial perspective and provide very pragmatic advice on complicated tax legislation and ever evolving case law.’

‘Elyse Waller is our lead contact and she is extremely personable, proactive, provides clear and concise advice on complicated tax matters, and is also extremely collaborative with both HMRC and other advisors working on our case.’

‘The EY team services all aspects of tax litigation.’

Principaux dossiers


  • Advised Biffa plc on a wide ranging and complex Landfill Tax enquiry.
  • Acted for Dolphin Drilling Limited at both the First-tier and Upper Tribunals on questions of whether a tender support vessel providing tender assisted drilling services in the North Sea is a ‘relevant asset’.
  • Acted for Thyssenkrup Materials (UK) Ltd in its appeal to the Upper Tribunal of the First-tier Tribunal’s decision in Thyssenkrup Materials (UK) Ltd v HMRC [2022] UKFTT 00443 (TC).

Eversheds Sutherland (International) LLP

Eversheds Sutherland (International) LLP has core expertise in indirect tax disputes, including VAT, APD, IPT, and customs duties, and is experienced working with both UK and international tax authorities. Giles Salmond, who is qualified as a barrister and solicitor advocate, specialises in international tax disputes, particularly indirect tax. Salmond leads the team alongside Ben Jones, who is co-head of global tax within the firm. Senior associate Edward Griffiths is praised for his 'extraordinary attention to detail.'

Responsables de la pratique:

Giles Salmond; Ben Jones


Autres avocats clés:

Edward Griffiths


Les références

‘The to go team when it comes to tax litigation – all over the technicals, but bringing unique insights and practical advice to help clients navigate the tax litigation landscape.’

‘Giles Salmond is exceptional – his in-depth knowledge of all things tax, importantly including customs and excise, means he is a safe pair of hands when it comes to all things tax disputes. His down to earth and practical advice is particularly appreciated by clients.’

‘Eversheds is an extremely strong law firm. They have showed a brilliant ability to step into some of the most complex areas of tax litigation, and thrive. They also foster excellent internal promotions, as is recently evidenced by Edward Griffiths being promoted to senior associate.’

Principaux clients

PriceWaterhouseCoopers LLP


Aozora GMAC Investment Ltd


Principaux dossiers


Hogan Lovells International LLP

Hogan Lovells International LLP‘s tax disputes offering works within the firm’s larger tax team and provides cross-sector services with key strengths in the technology, insurance, and real estate sectors. European tax disputes head Rupert Shiers leads the team. Shiers has broad tax litigation expertise and acts for both domestic and international clients.

Responsables de la pratique:

Rupert Shiers


Principaux dossiers


  • Advised a UK Publishing Group on an HMRC enquiry into the tax deductibility of expenses arising from legal claims for breach of privacy by staff and others working for the group.
  • Advised Gen Re on significant corporation tax losses arising from a group reorganisation.
  • Advised a US tech company on HMRC’s extensive information request for documents in respect of an intragroup refinancing of existing debt instruments in order to review the permissibility under the loan relationship rules.

Kingsley Napley LLP

Kingsley Napley LLP fields a team of ‘top-of the-range criminal lawyers’, highly experienced in high profile tax fraud cases, with a record of advising both individuals and corporates. The group has made a significant expansion to its civil tax litigation offering with the recruitment of new team lead Waqar Shah. Shah, who joined from Mishcon de Reya LLP in February 2023, is an ‘outstanding advisor and tactician’ with experience in judicial reviews and litigation from the Tax Tribunal to the Supreme Court. David Sleight is a financial crime expert with expertise in tax investigations.

Responsables de la pratique:

Waqar Shah


Autres avocats clés:

David Sleight; Alun Milford; Louise Hodges


Les références

‘Waqar Shah is extremely knowledgeable and beyond tax litigation finds time to update clients on general tax compliance matters which may be of relevance, so there is a real value-added service.’

‘The team is savvy, deeply experienced and highly attentive to the needs of clients.’

‘Waqar Shah is an outstanding advisor and tactician. He provides cool, calm and sophisticated insights into the issues facing his clients and then deals with those issues quickly and effectively. Waqar truly relieves clients of the burdens they carry and is the best advocate I have ever worked with.’

Principaux dossiers


Mishcon de Reya LLP

Mishcon de Reya LLP offers a comprehensive tax disputes service for corporate and private clients, with experience in both mediation and litigation. Team lead Robert Hartley covers direct and indirect taxes and handles both personal taxation matters as well as major transfer pricing enquiries. Leslie Allen, who was formerly department head, has over 35 years’ experience in the practice area and is a leading name in indirect tax litigation. Chartered tax adviser Paul Noble advises on cases relating to tax fraud, tax avoidance, and the disclosure of irregularities.

Responsables de la pratique:

Robert Hartley


Autres avocats clés:

Leslie Allen; Paul Noble; Tabassum Khan; Julius Berling; Cathal McLoughlin


Les références

‘Mishcon are one of the leading tax teams in the UK. They have a thorough knowledge of all tax issues and have excellent strength in depth.’

‘Leslie Allen is fantastic. He is extremely easy to work with, has excellent judgment and achieves brilliant results.

‘Very responsive and hands-on. Realistic and well-measured advice. Highly experienced in all manner of litigation. A pleasure to work with. Serve their clients extremely well.’

Principaux clients

Royal Mail Group Litigation


Zipvit Ltd


GE Aircraft Engine Services Limited


The Towards Zero Foundation


Principaux dossiers


  • Acted for the Claimants in the Royal Mail Group Litigation, the largest in the history of tax litigation, representing over 300 corporate entities and local authorities against Royal Mail (“RM”) with the overarching goal of holding RM accountable for its failure to meet its duty to issue valid VAT invoices to its customers.
  • Acted for GE Aircraft Engine Services Limited on the last successful VAT referral from the UK courts to the CJEU, concerning the VAT treatment of vouchers supplied to employees.
  • Acted for the Towards Zero Foundation in a dispute around what qualified as “business activities” for VAT purposes, which has potentially wide implications for charities.

Norton Rose Fulbright

Norton Rose Fulbright‘s tax team has key strength in international tax disputes, such as matters related to tax residence, challenges to international group structures, and the interpretation of double tax treaties. Global head of tax Dominic Stuttaford leads the team and advises domestic and international clients on a diverse range of contentious tax matters. Matthew Hodkin, who is head of the London tax team, advises on disputes with tax authorities, in addition to a broad non-contentious practice. Ruth Cowley has notable expertise in conducting external and internal investigations.

Responsables de la pratique:

Dominic Stuttaford


Autres avocats clés:

Matthew Hodkin; Ruth Cowley


Les références

‘Dominic Stuttaford: He 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.’

Principaux clients

HSBC


Takeda


Royal Bank of Canada


Principaux dossiers


  • Acted for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.
  • Acted for Takeda (formerly Shire) 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 utilises a broad range of dispute resolution techniques on behalf of clients, including mediation, ADR, and litigation. The group has broad tax expertise, with areas of strength including corporate residence, domicile, and transactions in securities legislation. David Pickstone leads the team and specialises in direct tax, environmental tax, and commercial tax litigation. Matthew Greene joined from Osborne Clarke LLP in June 2023, and has experience representing both corporate and individual clients. Tax director Lisa Vanderheide is a further key name.

Responsables de la pratique:

David Pickstone


Autres avocats clés:

Matthew Greene; Lisa Vanderheide; Anastasia Nourescu


Les références

‘Very approachable, sympathetic staff who engage with vigour and get to the root of issues quickly.’

‘Pragmatic and sensible approach, detailed knowledge, and very helpful advice.’

‘David Pickstone is highly commercial and technically very strong.’

Principaux clients

Tayto Group Limited


FCC Recycling UK Limited


John Jaekel


The Blair Partnership


The Noble Organisation


Singleton Birch Limited


Principaux dossiers


  • Advised Tayto Group Limited on a dispute with HMRC over an attempt to deduct goodwill which it says arose during a re-organisation of the wider Manderley Group.
  • Acted for FCC & Singleton Birch on appeal to the Tax Tribunal in respect of c.£10m assessment to Landfill Tax issued by HMRC regarding relevant waste.
  • Acted for a group of 110 investors in a claim against Andrew Thornhill KC that focused on written advice that was provided by Mr Thornhill in respect of the Scotts Atlantic Schemes, which was used by the promoters as part of their marketing efforts to encourage claimants to invest.

Weil, Gotshal & Manges (London) LLP

Weil, Gotshal & Manges (London) LLP handles a broad range of tax disputes, including international and cross-border matters. Leading the department are private equity expert Oliver Walker, Jenny Doak, who has key experience in indirect tax, Jamie Maples, whose areas of strength include the media, technology, and energy sectors, and solicitor advocate Christopher Marks.

Responsables de la pratique:

Oliver Walker; Jenny Doak; Jamie Maples; Christopher Marks


Principaux dossiers


Bark&co

Bark&co is a leading name in criminal tax matters, providing ‘an absolutely gold star service‘ on a broad range of high-profile and high-value fraud cases. The department also has strength in civil litigation, including VAT and excise duty cases. Firm founder and 'brilliant strategist' Giles Bark-Jones handles both criminal and civil matters. Peter Finbow‘s practice is focused on white-collar crime, including a broad range of fraud. Senior solicitor Maria Stalbow is experienced in complex and high profile corruption and fraud cases.

Responsables de la pratique:

Giles Bark-Jones


Autres avocats clés:

Peter Finbow; Sabrik Dhamu; Maria Stalbow


Les références

‘With expertise in both criminal and civil tax litigation – Bark&co really can offer a one-stop shop. Their market awareness is second to none. They always know what is going on in the wider space and how that might assist their client.’

‘Giles Bark-Jones is a legend. He has seen it all before, so nothing phases him – yet he still seems and driven and hungry as he did 20 years ago.’

‘Peter Finbow is efficient and well-versed in procedures and the applicable principles.’

Principaux dossiers


  • Acting for the directors of an online platform in relation to various allegations of tax evasion, amounting to £132m+.
  • Acting for four individuals charged in relation to an alleged £20m+ Conspiracy to Cheat the Public Revenue, committed between January 2017 and March 2022, through an infrastructure set up and operated by an Organised Crime Group.
  • 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 and valued at over £16m.

BCL Solicitors LLP

BCL Solicitors LLP has key strength at the intersection of fraud law and tax law, with a record of acting on complex and high-stakes matters. Lead partner Harry Travers, ‘one of the smartest lawyers in his field’, has a sophisticated fraud practice in addition to a long record in tax avoidance litigation. Firm founder Ian Burton and ‘expert in financial and tax crime’ John Binns are core team members. Senior associate Greg Mailer is also a name to note.

Responsables de la pratique:

Harry Travers


Autres avocats clés:

Ian Burton; Greg Mailer; John Binns; Anoushka Warlow


Les références

‘John Binns – expert in financial and tax crime matters. Good with clients.’

‘Powerful team across the whole spectrum of tax and investigations.’

‘Harry Travers has a real depth of interest and expertise in tax fraud investigations. He is a creative thinker and stoic defender of his client’s position. Harry is ably assisted by Greg Mailer who is developing his own standing as a tax investigation specialist.’

Principaux dossiers


Charles Russell Speechlys LLP

Charles Russell Speechlys LLP has strength in a range of areas, including tax-related professional negligence matters as well as trust and commercial disputes. The group acts for both corporate and private clients, both in the UK and offshore. Lead partner Hugh Gunson, described as ‘technically great, but also tactically astute’, has experience litigating tax at all levels.

Responsables de la pratique:

Hugh Gunson


Les références

‘CRS is very well known in the market and this is one of their strongest teams.’

‘Hugh Gunson – technically great, but also tactically astute. And very nice to work with.’

Principaux dossiers


Corker Binning

'One of the best white collar crime boutiques’, Corker Binning acts for clients facing major criminal tax charges, including those involving complex and international elements. Practice head Jessica Parker represents individuals, financial institutions, and other entities in both civil and criminal matters. Andrew Smith is an expert in AML matters.

Responsables de la pratique:

Jessica Parker


Autres avocats clés:

Andrew Smith; Nick Barnard


Les références

‘Well known as one of the best white collar crime boutiques and these days doing more work in the tax litigation field, particularly where there are allegations of fraud.’

‘Collaboration is excellent. They ensure that all the professionals are consulted and that both the full team and the client “buy in” to the proposed strategy.’

‘Peter Binning and Jessica Parke are very engaged and responsive, but also proactive and good at thinking “outside the box” for solutions to issues.’

Kuit Steinart Levy LLP

Kuit Steinart Levy LLP fields a team with both civil and criminal tax expertise, including a key aptitude in advising clients on the disclosure of funds held in offshore jurisdictions. Team lead Robert Levy is known internationally for his strength representing individuals facing tax investigations, including those involving serious fraud. Paul Bricknell is a key contact for tax disclosure work, while consultant Wendi Bussin covers regulatory and business crime.

Responsables de la pratique:

Robert Levy


Autres avocats clés:

Paul Bricknell; Wendi Bussin


Les références

‘Excellent law firm – very well run. I have referred numerous clients and all have been pleased with the standard of service.’

‘Robert Levy is the executive partner – his team think very highly of him, and he has a well-deserved reputation for integrity, wisdom and commercial sense. Wendi Bussin is an excellent tax investigations solicitor.’

‘Robert Levy is particularly well known. He is highly intelligent, affable, strategic, very client friendly and has seen it all before. Overall, a very good choice.’

Principaux dossiers


Osborne Clarke LLP

Osborne Clarke LLP‘s tax disputes team is particularly active in the technology sector, and handles a variety of employment tax matters. ‘First-class’ practice head Ian Hyde has over 30 years’ experience in the practice area, and advises clients on all aspects of tax litigation, including both civil and criminal matters. Consultant Frances Lewis specialises in tax risks related to off-payroll workforces. Associate director Katherine King covers professional tax negligence claims.

Responsables de la pratique:

Ian Hyde


Autres avocats clés:

Frances Lewis; Katherine King


Les références

‘Ian Hyde is an experienced corporate tax and VAT partner with a wealth of experience and knowledge, also in ADR. Bright, a great leader and a joy to work with.’

‘Ian Hyde is first class.’

Principaux clients

UBS


Domino’s Pizza Group PLC


Npower


Meta


Principaux dossiers


  • Advised a major UK staffing supply chain business in its appeal against a series of tax assessments totalling c. £10m.
  • Advised a digital currency service provider in relation to HMRC’s investigation of the company’s tax treatment of cryptocurrency trades.

Peters & Peters Solicitors LLP

Peters & Peters Solicitors LLP is experienced in handling parallel civil and criminal tax investigations, including cases with complex multijurisdictional elements. Practice head Neil Swift specialises in criminal tax fraud and civil cases involving a risk of criminal sanctions. Maria Cronin advises on FCA and money laundering cases. Of counsel Rachel Cook specialises in criminal tax litigation.

Responsables de la pratique:

Neil Swift


Autres avocats clés:

Maria Cronin; Rachel Cook


Les références

‘They are specialists in the area of white collar crime, and this enables them to give specific and appropriate advice and support.’

‘Clear strategic thinking and efficiency in implementation. Effective communicators and sympathetic case management.’

‘Very responsive and client friendly approach. Well networked beyond their immediate area of expertise. Focus as much on the personal aspects of advice as the technical.’

Principaux dossiers


  • Represented a high-profile entrepreneur charged with eight offences of avoiding VAT, causing an alleged loss of £22m to HMRC.

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

Skadden, Arps, Slate, Meagher & Flom (UK) LLP‘s tax controversy team works across Europe and the US on complex cross-border disputes, including EU-wide tax audits, transfer pricing matters, and major commercial disputes between private parties. James Anderson, who is head of the firm’s European tax practice, co-leads the team alongside international arbitration expert David Kavanagh KC. Kate Davies KC and Alex Jupp are further key names.

Responsables de la pratique:

James Anderson; Kate Davies KC


Autres avocats clés:

Alex Jupp


Les références

‘Technical expertise and in-depth knowledge of our business and structure. Finding solutions to difficult technical issues and seeing that advice right through to the end result.’

‘James Anderson – technically excellent, but offers pragmatic and commercial advice/solutions. Reliable and always available’

‘The team has extensive background and expertise in dealing with the taxing authorities. They also are able to call upon the experiences with other taxpayers in our case.’

Principaux clients

Victaulic


Vodafone


Principaux dossiers


  • Advising Victaulic on its appeal against the European Commission’s decision in the “excess profits ruling” cases in Belgium.
  • Advised a quantitative trading firm in connection with an advance pricing agreement (APA) on transfer pricing and PE issues for the 2022-2025 period, involving both UK and US tax authorities.
  • Advised a health technology company in connection with treaty, audit, settlement and strategic matters relating to a dispute with HMRC over pricing of royalties and financing transactions.