Tax

Tax disputes

The tax compliance climate has changed radically in recent years. At a domestic level, HMRC’s perception of avoidance (and, arguably evasion), what is the “right tax” – and what is not – and has changed out of all recognition and so HMRC is pursuing businesses for tax which would not have been pursued even a few years ago. Parliament has also granted HMRC significant new powers to demand information, collect tax even before it is shown to be due and require corporates to police other taxpayers.

Internationally, the taxation of multinationals has become a matter of public interest and the OECD and the BEPS project has changed the agenda but HMRC has been enthusiastic about getting ahead, introducing new legislation to ensure the UK’s share of tax is collected from international businesses.

This change in climate has led to a corresponding increase in controversies and litigation with tax authorities.

Our specialist tax disputes tax team can provide assistance and advice in all of the various stages of any tax dispute. Involved at an early stage, we can advise on investigations, information requests and settlement of claims. Where litigation is necessary we advise regularly on taking tax disputes to the Tax Tribunal, the High Court and appeals up to the Supreme Court and the Court of Justice of the European Union.

We also have specialist expertise in criminal prosecutions and Living Wage investigations.

On the international side, we have specialised teams across a number of jurisdictions in the fields of cross-border transfer pricing disputes as well as indirect taxation, VAT and customs. We are also very active in the discussion and negotiation of Advance Pricing Arrangements in different jurisdictions and multi-jurisdictional innovative transfer pricing schemes.

Experience


Healthcare corporation

Coordinated the tax investigations and audits of a publicly traded healthcare corporation, including competent authority settlement with consequences in Spain, US, France, Germany and Italy.

US-listed entity

Advised on an international tax arbitration before ICSID against a capital gains exit tax liability claimed by a local tax authority.

Multinational group

Advised on Advance Pricing Arrangements, covering patent box and cross-border transfer pricing global schemes, for a multinational group, specialised in fashion retail.

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