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Tax Disputes

Effective handling of relations with HM Revenue & Customs (HMRC) presents challenges. Managing tax disputes requires a clear understanding of both the dispute process and the tax technical issues. It is for this reason that we believe that specialist skills in both are required to provide best advice in this area.

Key Contacts

Other key Tax Disputes contacts

Our tax disputes specialists devote all their time to dealing with actual or potentially contentious tax matters. This enables them to prioritise and give full attention to the prevention and resolution of disputes in the most efficient, timely and cost-effective way. 

"Pinsent Masons brought a unique combination of skills to our tax dispute – technical accounting and commercial expertise, seamlessly blended with deep knowledge of the litigation process.  Their team also demonstrated invaluable insights into HMRC's approach, which gave us a firmer basis for important tactical and strategic decisions.   I do not believe that any other legal or accounting firm could have responded so effectively to our needs." said a director of one of our clients.

Members of our team have experience gathered in major law firms, HMRC, 'Big 4' accountants and large corporates.

Our experience is considerable and can give you a crucial tactical advantage. The vast majority of cases that we handle settle before reaching the Tribunal or the Courts and this remains our strategy in every case we undertake. As a result, our published credentials only represent the "tip of the iceberg" in terms of the range of work that we undertake - and the success that we achieve for our clients.

We are at the forefront of alternative dispute resolution in tax and two senior members of our team are CEDR accredited mediators.

We can also help corporates who have several tax disputes with HMRC to navigate their way through HMRC's global settlement programmes (HRCP and MCRP).

We will always seek to achieve settlement whenever possible. However, whenever necessary, we are well-equipped to fight HMRC on your behalf. We have done so time and time again in the First Tier Tribunal, the Upper Tribunal, the UK higher Civil Courts, the Court of Justice of the European Union and the Magistrates Court and Crown Court.

We can help businesses manage the cost of defending themselves against HMRC challenges by advising on funding options such as after the event (ATE) insurance. In advising on tax disputes we also frequently advise on bringing professional negligence claims against advisers.

If you are under investigation by HMRC or concerned about your tax compliance history, our Tax Investigations team can assist.

The US Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) mean that banks, insurers and trust and company service providers around the world are (or will soon be) obliged provide information about accounts held by non-residents, which, in the case of UK resident account holders, will be provided to HMRC. We have a specialist team that really understands FATCA and CRS and can help in relation to FATCA/CRS compliance.

We also frequently advise on urgent issues such as managing an HMRC dawn raid.

Some of our work is referred by tax professionals who require specialist assistance in resolving, or preventing, disputes on behalf of their clients. We believe that a collaborative, inclusive approach to other professional advisers is very much in the best interest of the client.

If you have an actual or potential issue with HMRC and you would like help with it, please contact us.

Recent Experience

  • Acting for UBS AG on its win in the Court of Appeal in HMRC v UBS AG [2014] EWCA Civ 452 concerning its employees incentive arrangements and acting for it in connection with HMRC’s appeal to the Supreme Court.
  • Acting for investors in a film partnership in a judicial review of HMRC's issue of partner payment notices in the case of Rowe and others v HMRC [2015] EWHC 2293 (Admin)
  • Acting for Secret Hotels2 Limited, a subsidiary of lastminute.com, in its win in the Supreme Court in a dispute of major interest to the holiday industry concerning the VAT treatment of online tour operators in HMRC v Secret Hotels2 Ltd (formerly Med Hotels Limited  [2014] UKSC 16.
  • Acting for Avon Cosmetics Limited in the First Tier Tribunal  in a case concerning the VAT regime for direct selling companies which has been referred to the CJEU in  Avon Cosmetics Ltd v Revenue & Customs [2014] UKFTT 172 (TC).
  • Acting for Mr Glyn in the First Tier Tribunal and Upper Tribunal on his appeal in relation to his UK residence status in James Glyn v Revenue & Customs [2013] UKFTT 645 (TC) and HMRC v Glyn [2015] UKUT0551 (TCC).
  • Acting for a number of large corporates faced with the prospect of a restriction of VAT recovery arising from 'missing trader' (MTIC) fraud in the supply chain.
  • Acting for BT Pension Fund Trustees in the Upper Tribunal in its foreign income dividend (FID) and tax credit group litigation The Trustees of the BT Pension Fund v HMRC [2013] UKUT 105 (TCC).
  • Acting for Mr Mayes (one of 70 participants in a tax scheme called SHIPS 2) in the Court of Appeal in Revenue & Customs v Mayes [2011] EWCA Civ 407, one of the only tax avoidance "schemes" to succeed before the courts in recent times. 
  • Acting for Weald Leasing Ltd in the Court of Appeal and the European Court of Justice in  Weald Leasing (Taxation) [2010] EUECJ C-103/09 concerning VAT and abuse of rights.