Herbert Smith Freehills LLP is one of the leading contentious tax teams in London undertaking a broad range of work including direct business tax, personal tax, employment tax and indirect tax disputes. The practice are increasingly focused on tax fraud matters with HMRC pursuing more criminal investigations and prosecutions. Nick Clayton leads the team and handles the full spectrum of tax disputes with a focus on tax fraud and investigations. Michael Hunt works closely with the employment team on contentious matters relating to worker status and internationally mobile employees. Associate Dawen Gao is a highly regarded practitioner.
Tax litigation and investigations in London
Herbert Smith Freehills LLP
Responsables de la pratique:
Nick Clayton
Autres avocats clés:
Michael Hunt; Dawen Gao
Les références
‘The team is extremely knowledgeable and approachable. They are able to translate ‘legalese’ into plain English and we have found them a pleasure to work with.’
‘Nick Clayton and Steven Wenham have been excellent in supporting our business. Quick to respond, very engaging and have very detailed knowledge and innovative solutions.’
Principaux clients
Uber
UBS
PacifiCorp
Awilco Drilling
Orsted
Principaux dossiers
Joseph Hage Aaronson LLP
Joseph Hage Aaronson LLP is a boutique dispute resolution firm which specialises in tax litigation, commercial litigation and international arbitration. The team acts in a number of high value recovery claims by major multinationals in complex domestic and cross-border tax disputes. The firm also have a growing expertise in cryptocurrencies and non-fungible tokens. Graham Aaronson KC founded the firm in 2013 and co-heads the practice with Michael Anderson who is experienced in running major tax disputes in non-UK jurisdictions. Simon Whitehead is well-versed in corporation tax matters, while Paul Farmer is an expert in European tax law.
Responsables de la pratique:
Autres avocats clés:
Les références
‘The team at JHA all seem to work together and work moves around the team seamlessly. They are all great at explaining complex legal matters in terms that can be understood by non-legal people.’
‘The stand out partner for me is Simon Whitehead who is always engaging on calls and provides sage advice and opinions.’
‘I have engaged with the JHA team for over 10 years. They have been assisting my company with a tax litigation. JHA are the experts in this matter. I have always found the team has been able to explain very complicated matters to me in a simple and understandable manner, and to fully engage with me as the case has developed over the years.’
Principaux clients
British American Tobacco
Marks & Spencer
Prudential
Intercontinental Hotels Group
Richemont
Akzo Nobel
GKN
Fidelity
JJ Management LLP
Shield Contract Services UK Ltd
Principaux dossiers
- Advised 25 UK headquartered multinationals in their challenge to the UK’s dividend taxation scheme.
- Advised Fidelity in relation to ongoing litigation in the Danish courts.
- Pursued Closure Notice Applications in the First-tier tribunal on behalf of a group of approximately 180 taxpayers.
Slaughter and May
The tax disputes team at Slaughter and May are frequently involved in high-profile tribunal cases and advise on mandates such as transfer pricing, state aid and tax residence. The firm undertakes both transactional and contentious matters with the ability to provide cutting-edge advice on evidence gathering, privilege and dealing with witnesses. Richard Jeens co-heads the practice with Dominic Robertson who regularly handles EU tax state aid investigations. Steve Edge is an accomplished contentious tax practitioner while Ewan Brown co-heads the global investigations group.
Responsables de la pratique:
Richard Jeens; Dominic Robertson
Autres avocats clés:
Ewan Brown; Steve Edge
Les références
‘Slaughter and May has a legendary tax team with an excellent reputation spanning many decades.’
‘This is an exceptional team with outstanding legal ability and analysis and a huge range of experience of all areas of tax and industry.’
‘Unrivalled technical expertise, knowledge and confidence in backing own position.’
Principaux clients
BlueCrest
GlaxoSmithKline
Mercuria Energy Europe Trading
Vodafone
Vitol
Principaux dossiers
- Advised the Vitol group in relation to anongoing transfer pricing and diverted profits tax (DPT) dispute with HMRC.
- Advised BlueCrest on several matters relating to challenges to the UK tax treatment of its management incentivisation arrangements.
- Advised Vodafone and GSK on the European Commission’s State aid investigation into the group financing exemption from the UK’s CFC rules.
Allen & Overy LLP
Allen & Overy LLP‘s contentious tax practice includes pre-litigation advice, negotiations and settlements with HMRC, commercial litigation proceedings and tribunal hearings. The firm has a varied client base with companies across the financial, consumer, retail, energy and transport sectors. Co-head Charles Yorke has experience of managing large-scale investigations by HMRC’s fraud investigation service. Vimal Tilakapala‘s practice involves finance-related tax including structured finance, regulatory capital and securitisation. Eve Giles specialises in financial crime investigations while Lydia Challen advises on supply chain finance and repackagings.
Responsables de la pratique:
Charles Yorke
Autres avocats clés:
Vimal Tilakapala; Eve Giles; Lydia Challen
Les références
‘Very high quality of people.’
‘Bright and hard working. They want to be involved in the detail and all the potential options.’
‘Charles Yorke in particular is extremely bright and thorough.’
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.
Ashurst
Ashurst has an active tax disputes practice which is considered a market leader in the context of VAT litigation, indirect tax, employment taxes, and EU State Aid. The firm primarily undertakes work for financial institutions, funds, premium corporates and infrastructure companies. Nicholas Gardner heads the team and has extensive expertise in relation to the resolution of disputes with HMRC and contentious tax matters generally. Paul Miller focuses on the financial services industry while Sara Mardell advises clients in relation to VAT and national insurance issues.
Responsables de la pratique:
Nicholas Gardner
Autres avocats clés:
Sara Mardell; Paul Miller
Les références
‘Continuity in the team over several years. The practice is solution oriented and able to set them into our case/issues to be solved. Likeable people with good collaboration.’
‘Expressed ownership and responsibility for our case. Senior associate major contact with outstanding performance.’
‘Very commercial with great technical knowledge. Knows when to use counsel and how to delegate to make best use of all resources and talents. Hard working. Sound. They will stand by their advice as well. Won’t plug aggressive planning that doesn’t work.’
Principaux clients
Imperial Brands PLC
Hastings Insurance Services Limited
Principaux dossiers
- Advised Mark Shaw as nominated partner of the TAL on his successful appeal to the Upper Tribunal from a decision made by HMRC to disallow certain claims for industrial buildings allowances.
- Advised Imperial Brands PLC on its appeal to challenge the EU’s decision that the UK CFC regime was unlawful state aid and that the UK should recover the benefit of the state aid from those groups.
Baker McKenzie
Baker McKenzie provides domestic and international tax disputes advice to multi-nationals with expertise across several sectors including financial institutions, healthcare, TMT and FMCG. The team is experienced in advising clients on European State Aid investigations, corporation tax disputes and transfer pricing matters. David Jamieson heads up the VAT and indirect tax disputes practice while Jessica Eden leads the corporate tax cases. Economist Nigel Dolman specialises in defending global transfer pricing and valuations across different industries. Patrick O’Gara has expertise in the pharma and life sciences sectors.
Responsables de la pratique:
David Jamieson; Jessica Eden; Nigel Dolman
Autres avocats clés:
Patrick O’Gara
Les références
‘A good team with sound tax technical knowledge and good strategic judgment.’
‘Baker McKenzie’s tax practice is unique because it is so closely integrated with the firm’s customs practice. As a result, the firm is a one-stop-shop for multinational companies seeking to base the customs values of their products on internal transfer prices between affiliates, which can be necessary but also trigger enhanced regulator scrutiny. Baker McKenzie lawyers are adept at working within a company’s existing transfer pricing/tax setup to find a customs valuation approach that will pass regulator scrutiny.’
‘This practice has people knowledgeable about UK tax law and procedures who were able to guide us through the new PDCF process and obtain a favorable outcome. They also were able to coordinate with offices in other countries to ensure favorable resolution.’
Principaux clients
Accenture
Baker Hughes
Core Media
Electronic Arts
European Tyre Enterprise Limited
Hutchison 3G Limited
Marriott
MDU (Medical Defence Union Limited)
UK Power Networks
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.
Bird & Bird LLP
The contentious tax team at Bird & Bird LLP assists clients throughout the full cycle of a dispute from providing pre-emptive compliance advice to making disclosures to relevant authorities and bringing civil litigation. The team deals with tax authorities in relation to all types of issues including transfer pricing and diverted profit matters. Andy Brown heads the practice and specialises in cross-border disputes while Chris Young is well-versed in areas such as money laundering.
Responsables de la pratique:
Andy Brown
Autres avocats clés:
Chris Young
Les références
‘This team is unique because it has a wealth of experience in this field and can draw upon a diverse experience of inter connected and related practice areas. I have worked with the team on matters that have included internal investigations, civil/criminal cross over cases, as well as matters that have progressed to criminal prosecutions by HMRC. The team therefore sets itself apart from its competitors.’
‘Andy Brown heads the team and is impressive. He has vast experience and is particularly well organised and is able to break down complex issues into their most important parts. In addition, he is adept at providing practical advice to the firm’s clients. The associates in the team are high level, notably Chris Young.’
‘They are sophisticated and practical at the same time which is relatively rare in their field. Cross border tax disputes and remediation in the context of M&A is normally the preserve of the Big 4. This team however is very adept at creating a process and structure which will help a deal happen when tax might otherwise have caused it to abort.’
Principaux clients
B&M Retail
Sporting Wholesale Limited
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 through the contractual disclosure facility for deliberate overclaiming monies under the coronavirus job retention scheme.
- Advised a UK subsidiary of a South Korean business in relation to recovery of over £20m of input VAT and the zero-rating of luxury fashion goods to South Korea.
Bryan Cave Leighton Paisner
The contentious tax practice at Bryan Cave Leighton Paisner, overseen by global head Elizabeth Bradley, covers the full spectrum of matters with increased focus on corporation tax and employment tax disputes as well as tax fraud issues. Kate Ison specialises in contentious tax with expertise in marketing and technology sectors. Alan Sinyor is a VAT practitioner and deals with high value and cross border VAT disputes with HMRC.
Responsables de la pratique:
Elizabeth Bradley
Autres avocats clés:
Kate Ison; Alan Sinyor
Les références
‘Very efficient and responsive. Practical and down to earth, whilst being very reassuring to the clients.’
‘Kate Ison is terrific – clever, sensible, hard working and very efficient. She has absolutely no edge or ego.’
‘There is a very good synergy between the commercial litigators and the VAT team. Each play to their strengths which significantly improves their offering to the client.’
Principaux dossiers
Clifford Chance LLP
Clifford Chance LLP‘s contentious tax practice has expertise in complex international and cross border investigations and disputes involving VAT. Recent highlights include advising in relation to a dispute around the tax treatment of foreign tax credits. Co-head David Saleh has particular expertise in real estate-related taxes while other co-head David Harkness specialises in corporate and finance tax. Associate Nicola Hemsley focuses on tax disputes with clients such as financial investors and institutions.
Responsables de la pratique:
David Saleh; David Harkness
Autres avocats clés:
Nicola Hemsley
Principaux clients
Major banks
Investment funds
Corporate entities
Principaux dossiers
Fieldfisher
The contentious tax team at Fieldfisher has expertise in a variety of tax disputes topics including disclosures, resolution of HMRC enquiries, criminal enquiries and professional negligence claims. There is also a substantial international element to the work being done evidenced by frequent dealings with German tax authorities. George Gillham co-heads the practice with Derek Hill who had expertise in the media and film sectors. Barrister and partner Philippe Freund is involved in cases ranging from the Tax Tribunals to the Supreme Court. Matthew Sharp specialises in contentious tax matters.
Responsables de la pratique:
Derek Hill; George Gillham
Autres avocats clés:
Philippe Freund; Matthew Sharp
Les références
‘George Gillham is one of the best tax litigators around, highly experienced with excellent background in tax work.’
‘Excellent technical knowledge as well as practical experience in dealing with HMRC.’
‘Matthew Sharp is both technically excellent and has strong client service skills.’
Principaux clients
Invamed Group Ltd
Sunrise Medical Ltd, Invacare Ltd
Roma Medical Ltd
Days Healthcare Lt
Drive deVilbiss Healthcare Limited
Sunrise Medical Ltd
TGA Mobility Limited
Electric Mobility Euro Limited
Aramark Limited
Sunrise Medical BV & Sunrise Medical Logistics, B.V.
Principaux dossiers
- Advised Sunrise Medical Ltd, Electric Mobility Euro Ltd, TGA Mobility Ltd, Drive DeVilbiss Ltd on a £6,000,000 Group Litigation before the FTT.
KPMG Law in the United Kingdom
The tax disputes and investigations team at KPMG Law in the United Kingdom acts on all types of domestic and cross-border matters including corporation tax, customs and excise duties and income tax for high net-worth individuals. Recent highlights include representing HSBC in a novel dispute about non-incorporated entities which has far-reaching consequences for UK VAT law. Angela Savin has a range of direct tax dispute resolution expertise and co-heads the team with Matthew Fleming who leads the indirect tax disputes practice. Amanda Brown KC is a rated barrister who represents clients in a range of disputes.
Responsables de la pratique:
Angela Savin; Matthew Fleming
Autres avocats clés:
Amanda Brown KC
Les références
‘The team is highly efficient, and very commercial in its attitude. Very high degree of expertise in the field.’
‘A large tax focused team with a great deal of depth and knowledge.’
‘KPMG’s tax investigations team is very experienced and are astute in dealing with HMRC investigations.’
Principaux clients
Cape Industrial Services Limited
Devon Waste Management
DHL Air Ltd
English National Ballet
Euromoney plc
Gap Group Limited
Gloucestershire Hospitals NHS Foundation Trust
John Hargreaves
HSBC Bank plc
Intercontinental Hotels
Jupiter Asset Management plc
Key Group Limited
Kopparberg
Lloyds Banking Group
Poundland Limited
Robert Wiseman and Sons Limited
Silver Seas Property Holdings Sarl
Thyssenkrupp Materials (UK) Limited
United Grand Lodge of England
Volkswagen Financial Services (UK) Limited
William Archer
William Hill plc
Principaux dossiers
- Represented HSBC in a novel and untested VAT law dispute with HMRC.
- Represented John Hargreaves in challenging the competency and validity of a discovery assessment which was made by HMRC for income and capital gains tax.
Macfarlanes LLP
Macfarlanes LLP advises on the full spectrum of tax matters from HMRC enquiries to audits, investigations and litigation. The team handles both direct and indirect tax disputes with many going before the tax tribunals and civil courts. Other areas of expertise include transfer pricing and offshore trusts matters. Gideon Sanitt heads the team with experience in both transactional and contentious work with support from Sebastian Prichard Jones. Ben Webster acts on a wide range of tax disputes including traditional HMRC matters and judicial review cases.
Responsables de la pratique:
Gideon Sanitt
Autres avocats clés:
Sebastian Prichard Jones; Ben Webster
Les références
‘The quality of solicitors working in the team are able to attract top quality private clients. The litigation and investigations team fits very well with the private client teams to resolve disputes with HMRC.’
‘Very hard working. Substantial experience in litigation and investigations. Very high quality recent hires from HMRC.’
‘Exceptionally hard working. Technically brilliant. Savvy litigators.’
Pinsent Masons LLP
Pinsent Masons LLP‘s tax disputes and investigations team advise several large companies on IR35 legislation and international tax issues such as diverted profits tax. The practice do a lot of work in the energy sector on matters such as the Construction Industry Scheme (CIS). The firm are also strong in handling employment and business crime tax-related issues. Steven Porter heads the practice and has a wealth of experience in contentious and non-contentious tax matters. Andrew Sackey is experienced in domestic and international investigations, while Jake Landman specialises in tax disputes and advising large corporates.
Responsables de la pratique:
Steven Porter
Autres avocats clés:
Andrew Sackey; Jake Landman
Les références
‘The ability to have specialist legal expertise in-house was a key attraction for the firm, as was their knowledge and expertise of the industry sector.’
‘Strong Case management. Very responsive to questions. Very conscious of costs management.’
‘The team take time to understand how our business operates and its priorities. There is a great breadth of knowledge and the capability to adapt the way they work to suit business need. They work hard to become an extension of our business on the matters where we instruct them.’
Principaux clients
Raymond Tooth
Natwest Group
Cantor Fitzgerald
The Gala Film Partners LLP
Centrica
Darty Limited,
E-zec Medical Transport Services Ltd
Principaux dossiers
- Acted for Raymond Tooth in proceedings before the Tax Chamber of the First-tier Tribunal, Upper Tribunal and Court of Appeal.
- Advising on the MOD’s group action who are challenging a discriminatory UK WHT suffered on certain income derived from lending non-UK shares.
- Acted for NatWest Group in an £86 million VAT dispute with the potential for a further penalty up to 100% of the VAT.
PwC LLP
PwC LLP has a large contentious tax team consisting of solicitors, barristers, accredited mediators, CTAs and accountants. The team provides expertise across a number of sectors such as financial services, retail, gaming, manufacturing, telecommunications, leisure and education. The team is frequently involved in tax litigation, tax investigations, transfer pricing and ADR work covering multiple jurisdictions. Stephen Morse leads the practice with experience in direct tax, VAT, transfer pricing and personal taxes. Mark Whitehouse has expertise in tax planning challenges, HRCP cases, corporate tax appeals and judicial reviews. David Anderson is well-versed in contentious and non-contentious matters.
Responsables de la pratique:
Stephen Morse
Autres avocats clés:
David Anderson; Mark Whitehouse
Principaux clients
General Electric
IHS Markit
Worldpay, Inc / FIS Global
Telent Technology Services
Dollar Financial UK Limited
Brett Aggregates Limited
Hippodrome Casino Limited
General Electric Pension Funds
Jazztel plc
Principaux dossiers
Quinn Emanuel Urquhart & Sullivan, LLP
Quinn Emanuel Urquhart & Sullivan, LLP has expertise in sensitive taxation and financing-related matters. The practice is experienced in regulatory and high-net worth tax investigations, arbitration disputes and multi-jurisdictional challenges faced by UK-based or UK-connected nationals. Practice head Liesl Fichardt specialises in complex tax, finance and debt-related investigations with HMRC. Epaminontas Triantafilou frequently represents clients in international arbitrations while associate Emily Au assists with forensic tax investigations.
Responsables de la pratique:
Liesl Fichardt
Autres avocats clés:
Epaminontas Triantafilou; Emily Au
Les références
‘The firm is one of the leaders in international and cross-border tax disputes.’
‘Liesl Fichardt is a phenomenal tax disputes lawyer with a fantastic knowledge and experience of cross-border taxation issues affecting corporations and corporate groups. She has a stellar reputation and client list to match. A brilliant team leader, an astute negotiator, incredibly accessible and user-friendly and always focused on securing the right commercial result for best value.’
‘This team bring, to UK tax litigation, the guts and determination which are the hallmarks of US litigators and marries it with the huge experience and management skill of Liesl Fichardt who has great knowledge of managing group litigation. The team also has the research skills and the depth of knowledge properly to analyse a problem and to bring it successfully to trial.’
Principaux clients
Lockton Group Companies
Premier Team Holdings Ltd
The Trustco Group
Global Media / Bauer Media
Radiocentre Limited
Barrick Gold Corporation Group and international subsidiaries
Anglo Gold Ashanti
Principaux dossiers
- Advised Saracens Rugby club in complex tax and regulatory disputes.
- Provided ongoing advice to Canadian – UK Barrick Gold in their billion dollar tax disputes against the Tanzanian Government.
- Advised Trustco Ltd in a complex appeal currently pending before the Court of Appeal.
RPC
The tax litigation team at RPC has extensive experience in all aspects of HMRC investigations with a particularly strong sports and entertainer client base. The team is instructed in some of the largest UK and European Court of Justice tax cases in addition to representing several taxpayer companies and individuals in public law group actions against HMRC. Adam Craggs heads the practice and has particular expertise in dealing with enquiries and complex tax litigation. Robert Waterson focuses on multijurisdictional disputes while Michelle Sloane advises both corporates and high-net worth individuals. Associate Harry Smith has experience across a range of direct and indirect taxes.
Responsables de la pratique:
Adam Craggs
Autres avocats clés:
Robert Waterson; Michelle Sloane; Harry Smith
Les références
‘Expert knowledge on technical tax issues, dealt with efficiently.’
‘Good communication skills.’
Principaux clients
TSB Plc
Frasers Group PlC
Universal Cycles
Metropolitan International Schools Ltd
Newcastle United Football Club
Steven Hoey
Clipperton & Lloyd
AML Tax (UK) Ltd
Jones Bros Ruthin (Civil Engineering) Co Ltd
Britannia Hotels Limited
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.
Simmons & Simmons
Beyond the mainstream tax tribunal litigation, Simmons & Simmons specialises in commercial tax litigation, e-discovery, regulatory investigations, fraud work and professional negligence. The firm has sector expertise in the asset management, TMT, healthcare and life sciences industries. Nick Skerrett leads the team and is experienced in litigating high-value tax cases. Monique Van Herksen specialises in transfer pricing controversy and dispute resolution. Heather Rowlands advises corporate clients on VAT disputes.
Responsables de la pratique:
Nick Skerrett
Autres avocats clés:
Monique Van Herksen; Heather Rowlands
Principaux clients
Augean plc
Veolia
Christopher Rokos
Fidelity
Halfords
Principaux dossiers
- Acted for Chris Rokos in High Court professional negligence proceedings against Deloitte LLP and McDermott Will & Emery LLP.
- Advised two of the four parties to the Devon Waste Management litigation on appeals that are collectively worth around £6 billion to the landfill sector.
- Acting for Augean plc on appeals against landfill tax assessments imposed by HMRC, a case of general significance to the landfill sector.
DLA Piper
DLA Piper helps clients to manage complex civil and criminal fraud investigations while also providing contentious tax expertise. The practice has been significantly strengthened in recent months by a series of hires from Pinsent Masons LLP, including international tax controversy head Jason Collins and senior associate Lauren Redhead in 2021, followed by legal director Clara Boyd and Stuart Walsh in 2022, further boosting the team’s expertise in relation to contentious VAT and excise duty matters. Richard Woolich covers indirect tax issues such as excise duty, carbon pricing and landfill tax in addition to transfer pricing matters.
Responsables de la pratique:
Jason Collins
Autres avocats clés:
Lauren Redhead; Richard Woolich; Clara Boyd; Stuart Walsh
Les références
‘Very experienced in relation to commercial tax issues and litigating against HMRC.’
‘Jason Collins is fantastic. The team has huge all round tax knowledge.’
‘Jason Collins is a really top tax professional who has bags of knowledge and experience.’
Principaux clients
Mid Ulster District Council
JVM Equipment Limited
Westland Horticulture Limited
Principaux dossiers
- Acted for Mid Ulster District Council in its successful appeal for refunds of wrongly paid VAT on leisure and recreational services before the First-tier Tribunal.
- Represented JVM Equipment Limited in connection with a Transfer Pricing and Diverted Profits Tax dispute.
- Acted for Westland Horticulture in a Tribunal appeal and Judicial Review proceedings regarding the VAT treatment of grass seed and HMRC’s published guidance.
Ernst & Young LLP
Ernst & Young LLP acts for clients in the largest and most complex tax disputes in litigation from the First-tier Tribunal to the Supreme Court. The firm’s client base ranges from ultra-high net worth individuals to corporates with a particular strong presence in the oil and gas sectors. Boaz Goren leads the direct tax litigation practice with a wealth of experience practicing as a tax and commercial litigator. Other head Mitchell Moss leads the indirect tax practice with dispute resolution experience in VAT. Julian Balson assists clients in tax-related enquiries, investigatons and proceedings.
Responsables de la pratique:
Boaz Goren; Mitchell Moss
Autres avocats clés:
Julian Balson
Principaux clients
Biffa Waste Services Limited
Dolphin Drilling Limited
Principaux dossiers
- Advised and represented Biffa Waste Services Limited at the FTT, UT and Court of Appeal on a dispute in relation to the landfill tax treatment of a certain material.
- Advised and represented Dolphin Drilling Limited at the FTT in relation to its dispute with HMRC regarding the application of Part 8ZA of Corporation Tax Act 2010 (CTA 2010) to a particular offshore oil drilling support asset.
Eversheds Sutherland (International) LLP
Eversheds Sutherland (International) LLP provides practical contentious tax advice on issues such as VAT, customs duties, loan relationships, SDRT and tax investigations. In addition the team has expertise in acting for clients in judicial reviews and advising on precedent-setting cases of tax discrimination. David Jervis co-heads the team with Giles Salmond who specialises in indirect tax with a focus on contentious VAT. Edward Griffiths advises clients on disputes with HMRC from pre-action through to trial.
Responsables de la pratique:
Giles Salmond; David Jervis
Autres avocats clés:
Edward Griffiths
Les références
‘Very approachable.’
‘Edward Griffth is very approachable and gives timely updates.’
‘An engaging and client focused team offering practical yet cutting edge strategic advice on contentious tax issues. Giles leads an excellent technically strong team who are all very pleasant to deal with.’
Principaux clients
PriceWaterhouseCoopers LLP
Aozora GMAC Investments Limited
Principaux dossiers
Hogan Lovells International LLP
Hogan Lovells International LLP has an extensive tax litigation and investigation offering with expertise in the tech, insurance and real estate sectors. The practice are known for HMRC enquiries and internal investigations with a number of US groups among the client base. Rupert Shiers leads the UK and European tax litigation team with expertise in taxpayers rights, HMRC powers and tax statutory interpretation.
Responsables de la pratique:
Rupert Shiers
Principaux dossiers
- Advised Fortune 500 and FTSE 100 defined benefit pension schemes on resolving their position in multi-party VAT litigation, actively managed by the Tribunal.
- Advised Eynsham Cricket Club on Court of Appeal VAT litigation, addressing zero-rating, interaction of VAT and fundamental points of statutory interpretation.
Mishcon de Reya LLP
The tax disputes and investigations team at Mishcon de Reya LLP spans both indirect and direct tax with both corporate and private clients. ADR and mediation continues to be a key focus of the teams practice as the practice advises on all aspects of dispute resolution from early stage written representations through to a Tribunal hearing. Team head Leslie Allen is experienced in the conduct of indirect disputes and is supported by Robert Hartley who advises clients across the real estate and leisure sectors. Paul Noble specialises in resolving complex tax disputes.
Responsables de la pratique:
Leslie Allen
Autres avocats clés:
Robert Hartley; Paul Noble
Les références
‘Mishcon’s tax team is right at the top of the tree. They are involved in the most important and high value cases in this area. They have strength throughout their team.’
‘Leslie Allen has years of experience. He is excellent to work with, and is both clever and pragmatic.’
‘We have used Mishcon for specialist tax advice regarding a dispute with HMRC for which they have the appropriate skills, knowledge & experience.’
Principaux clients
Royal Mail Group Litigation
Zipvit Ltd
Iceland Foods Limited
Principaux dossiers
- Represented over 300 corporate entities and local authorities against Royal Mail.
Norton Rose Fulbright
Norton Rose Fulbright has extensive experience in advising taxpayers in relation to tax authority investigations, negotiations with tax authorities, public law remedies and matters before the major UK courts and tribunals. The team also carries out work with an international element including challenges to international group structures and tax residence. Practice head Dominic Stuttaford is an experienced tax litigator while Chris Bates is regularly instructed on HMRC investigations. Michael Alliston advises taxpayers on tax governance and compliance matters.
Responsables de la pratique:
Dominic Stuttaford
Autres avocats clés:
Chris Bates; Michael Alliston
Les références
‘A down to earth and super dedicated and talented team with great reputation, standing and industry knowledge.’
‘A stand out team that offers great client centered and commercial advice combined with the outstanding legal skills of a leading City law form.’
‘I have worked with Dominic Stuttaford, partner, on many occasions and admire his great experience, knowledge and manner.’
Principaux clients
BMW
HSBC
Lloyds Banking Group
Takeda
Royal Bank of Canada
DP World
Principaux dossiers
- Acted for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.
- Acted for Takeda in a restitution claim in the Stamp Taxes Group Litigation Order relating to Stamp Duty Reserve Tax.
- Acted for Royal Bank of Canada in relation to a dispute with HMRC concerning the taxation of North Sea Oil royalties.
Stewarts Law LLP
Stewarts Law LLP acts on a multi-disciplinary basis across four specialist areas of tax disputes including direct tax litigation, indirect tax litigation, tax investigations and commercial tax litigation. The department is well-versed in tax and HMRC settlement with a diverse client base from high-net worth individuals and associated businesses. David Pickstone is experienced in direct tax, environmental tax and commercial tax litigation. Lee Ellis acts for corporates while Victor Cramer focuses on indirect tax.
Responsables de la pratique:
David Pickstone
Autres avocats clés:
Lee Ellis; Victor Cramer
Les références
‘Excellent relationship with HMRC which assists clients in getting to heart of dispute quickly. Former HMRC senior officers on the team help understand HMRC thinking. Very accessible and responsive partners.’
‘Partner Lee Ellis has exceptional grasp of complex and technical issues, leverages his in house experience at HMRC Solicitors Office wisely and gives clients great insight into the mindset of Revenue.’
‘Stewarts key strengths are their extensive experience and in-depth knowledge of tax litigation which enables them to give insightful, pragmatic and exceptional strategic advice in addition to first class technical tax advice. This in my view is what makes the team stand out from other legal advisers.’
Principaux clients
Quinn (London) Ltd
The Claims Guys Ltd
Tayto Group Limited and Others
FCC Recycling UK Limited and Singleton Birch Limited
John Jaekel
Marchill Investments LLP
A Banking & Finance Industry Body
Neil Blair / The Blair Partnership
Principaux dossiers
- Acted Quinn (London) Ltd in a leading tax appeal which found for our clients and rejected HMRC’s attempts to narrow the scope and availability of R&D relief to small and medium-sized enterprises.
Weil, Gotshal & Manges (London) LLP
The tax litigation team at Weil, Gotshal & Manges (London) LLP is 'thorough, efficient, organised and all-round great to work with‘. The practice frequently advises clients on the merits of pursuing litigation against tax authorities and the interaction between insurance cover and the decision to settle a claim. The firm’s key lawyers include disputes expert Jamie Maples , Jenny Doak and Oliver Walker who advises private equity and pension funds. Chris Marks regularly advises clients in relation to pre-dispute strategy.
Responsables de la pratique:
Oliver Walker; Jenny Doak; Jamie Maples; Christopher Marks
Les références
‘Working with this team, what marks them out is their clarity of instruction and commercial acumen.’
‘I found their instructions clear and well reasoned and the case was well prepared.’
‘The associate I have worked closely with is Stuart Pibworth, a very bright person with good judgment and a commercial manner.’
Principaux clients
Littlewoods Group
Joint Special Administrators of MF Global UK
Advent International
Providence Equity Partners
Bark&co
Bark&co has expertise in civil tax and criminal tax fraud with an increasing focus on litigation in areas of VAT and excise duty. Giles Bark-Jones leads the practice with expertise extending to several areas of civil litigation including fraud and contentious tax. Peter Finbow specialises in white-collar crime including VAT fraud and money laundering.
Responsables de la pratique:
Autres avocats clés:
Peter Finbow
Les références
‘In my view, Bark and Co is one of the pre-eminent firms in both areas of criminal practice (fraud and general crime) with great strength and depth in the team. They also have a very effective tax/civil department that compliments what they do, particularly with regard to fraud.’
‘As stated above the firm has great strength and depth. I would wish to single out Giles Bark-Jones who remains the back bone of the firm and very much in control of the whole show. He is an excellent lawyer and very much the power house that drives the firm forward and ensures that it provides the excellent quality of service that it does.’
‘Bark & Co’s is one of the leading boutique white-collar crime firms, with particular experience of investigations and prosecutions relating to tax frauds, meaning that they have a wealth of expertise in dealing with tax investigations and the litigation that flows from it.’
Principaux dossiers
- Acted for an individual in investigations by the National Crime Agency and SKAT into fraud and money-laundering activities worth over £1.5bn committed against the tax authorities in a number of European countries.
- Acted for one of a number of individuals alleged to have been part of an OCG into which HMRC conducted an intensive investigation concerning a long-running conspiracy to cheat the public revenue along with ancillary money laundering offences.
- Acting for one of a number of individuals charged in relation to an alleged alcohol diversion fraud operated on a massive scale in 2009 and 2010.
BCL Solicitors LLP
The business crime and regulation team at BCL Solicitors LLP acts for a range of clients including high-ranking executives and senior figures. The firm has expertise in tax fraud cases across the financial and legal sectors. Co-head Harry Travers combines experience in tax litigation and tax fraud. Other co-heads Ian Burton and Greg Mailer are involved in tax investigations while John Binns represents individual and corporate clients.
Responsables de la pratique:
Harry Travers; Ian Burton; Greg Mailer
Autres avocats clés:
John Binns
Les références
‘Unparalleled expertise in the financial crime space. Consistently delivering outcomes above and beyond those that could be reasonably anticipated.’
‘Harry Travers combines a very powerful analytical mind, with deep technical skills and industry leading experience. Harry works tirelessly to ensure clients benefit from the best possible outcomes in the hazardous environment of serious tax investigations.’
‘Greg Mailer has strong technical skills and is a very skilled negotiator and problem solver. Greg is a very safe pair of hands in the daunting environment of serious tax investigations.’
Principaux dossiers
Charles Russell Speechlys LLP
Charles Russell Speechlys LLP are known for their ability to offer expert advice on HMRC enquiries, investigations and litigation including claims for mistake and rectification both in the UK and offshore. Hugh Gunson heads the practice and covers the full spectrum of work including corporation tax and CGT.
Responsables de la pratique:
Hugh Gunson
Les références
‘Excellent attention to detail and commerciality.’
‘Hugh Gunson has shown a very pragmatic and commercial approach and his attention to detail is highly impressive, which inspires confidence in his handling of affairs.’
‘This is a technically excellent and highly responsive team. The tax litigation team was able to work seamlessly with the private client team to provide a joined up offering.’
Principaux clients
Nicola Mackay
Principaux dossiers
- Acted for Nicola Mackay in an application to the High Court to set aside her appointment as trustee of a trust on one of a number of grounds.
- Advised a client in relation to a very complex and high value disclosure to HMRC in relation to unpaid tax liabilities and a related professional negligence claim.
- Advised three brothers in relation to an HMRC investigation under Code of Practice 9 (COP 9) into their personal tax affairs, involving high value offshore trusts.
Kingsley Napley LLP
Kingsley Napley LLP represents individuals in cases involving allegations of tax avoidance and indirect taxation matters such as VAT claims and settlements. The firm also has a good reputation for advising on high-profile tax fraud cases and white collar crime. The key names include financial crime expert David Sleight and Louise Hodges, who frequently handles tax investigations. Ed Smyth acts for individuals and corporates in respect of criminal cases.
Responsables de la pratique:
Autres avocats clés:
Ed Smyth; Louise Hodges; David Sleight
Les références
‘The team at KN has an incredibly client focused approach, the client is always number one. The team is always thinking about what is best for the client, how issues can be best communicated and how they can put together the right group of professional representatives. The pursuit of excellence in this way is massively reassuring for clients and gives them real confidence that their case is being dealt with properly and promptly.’
‘The team also has lawyers of the highest quality, who seek to learn and get better at what they do.’
‘They are just so impressive and I would recommend them to anyone.’
Principaux dossiers
Kuit Steinart Levy LLP
The tax investigations team at Kuit Steinart Levy LLP represents clients in relation to a range of issues including tax scheme investigations, furlough fraud, settlement of scheme liabilities and cases involving tax data theft. Practice head Robert Levy has expertise in representing clients facing tax investigations while Paul Bricknell specialises in tax disclosure matters.
Responsables de la pratique:
Robert Levy
Autres avocats clés:
Paul Bricknell; Wendi Bussin
Les références
‘Knowledge, experience and client care from a team who really put their clients’ best interests first. We have worked alongside this team and they are impressive.’
‘The firm is well known in this area with good technical tax knowledge and known for excellent client care.’
‘Robert Levy is popular, collegiate, technically able, experienced and strategically astute.’
Principaux dossiers
Osborne Clarke LLP
Osborne Clarke LLP often advises on tax related litigation matters with expertise in the off payroll and flexible workforce sector. The team is especially active in the technology and financial services sector. Ian Hyde leads the team and represents clients in all aspects of tax risk and tax litigation. Frances Lewis is experienced in advising staffing companies on tax status issues.
Responsables de la pratique:
Ian Hyde
Autres avocats clés:
Frances Lewis
Les références
‘This is a tightly-focused team, able to deliver in relation to tax disputes and advisory matters across all taxes. Great at collaborating and innovative in relation in particular to disputes work and Alternative Dispute Resolution with HMRC.’
‘Ian Hyde in particular is a standout individual. He is a part-time tribunal judge and CEDR-accredited mediator as well, so he has real insight to offer in terms of dispute resolution with HMRC and how a court or tribunal might view any given case. He is personable and efficient, as well as being a technical expert.’
‘Ian Hyde combines technical knowledge with a real feel for litigation.’
Principaux clients
UBS AG
Domino’s Pizza Group PLC
Npower
Principaux dossiers
- Represented a client in an appeal to the Tax Tribunal following HMRC’s investigation into the historic VAT recovery and partial exemption position.
- Advised an accountancy service company in HMRC’s investigation into the application of the Managed Service Company anti-avoidance legislation to a structure for managing self-employed contractors.
- Advised an international recycling group on an HMRC investigation into treatment of import and export of recycled automotive parts and whether the exports to Europe qualified for zero rating.
Peters & Peters Solicitors LLP
Peters & Peters Solicitors LLP‘s tax team specialises in civil and criminal disputes with extensive experience in handling investigations and liaising with HMRC. Many of the firm’s cases have an international element such as overseas tax law or offshore tax structures. Practice head Neil Swift has expertise in criminal tax fraud and civil cases. Maria Cronin provides clients with advice in FCA and money laundering matters.
Responsables de la pratique:
Neil Swift
Autres avocats clés:
Maria Cronin
Les références
‘The practice seem to show true understanding and compassion for my situation and I felt went above and beyond, day or night to put my mind at ease.’
Principaux clients
High Profile entrepreneur
Two Chinese citizens and their company
Principaux dossiers
- Acted for two Chinese citizens and their UK incorporated company in a large-scale money laundering investigation.
Skadden, Arps, Slate, Meagher & Flom (UK) LLP
The European tax controversy group at Skadden, Arps, Slate, Meagher & Flom (UK) LLP resolves high-value matters for clients that include corporations, partnerships, estates, individuals and government entities. The team has experience in areas such as transfer pricing, case-management for EU-related tax and state aid claims. James Anderson co-heads the practice with David Kavanagh who has expertise in litigation and arbitration.
Responsables de la pratique:
James Anderson; David Kavanagh KC
Les références
‘Skadden, Arps, Slate, Meagher & Flom was instrumental in fielding a counterclaim in an arbitration where they did literally “dig out” tax and financial information hidden by the Claimant.’
‘David Kavanagh had a superb grasp of the financial and tax implication of the obvious and non-obvious aspects of the case.’
‘Strong consistent team with deep knowledge in their specialism and of our business.’
Principaux clients
Vodafone International Holdings BV
Kingfisher plc
Victaulic Europe BV
Megapolis
Anadarko
Principaux dossiers
- Represented Vodafone in its $5.5 billion dispute with India in one of the most high-profile bilateral investment treaty (BIT) disputes.
- Acted as state aid counsel for Kingfisher plc in connection with the European Commission’s investigation into the group financing exemption in the UK’s former controlled foreign company (CFC) rules.