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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.

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 one of the partners in our team is a CEDR accredited mediator.

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 obliged to 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 RBS on two major VAT disputes arising from missing traders in its supply chains, including Bilta v RBS [2017] EWHC 3535 (Ch), an important decision in relation to legal privilege and tax disputes.
  • Acting for Molson Coors in their recent success in the First-Tier Tax Tribunal MCBC v HMRC  [2017] UKFTT 342 (TC).
  • Advising on the ground-breaking judicial review challenge in Rowe v HMRC, concerning HMRC’s new accelerated payment notice powers for a group of 183 taxpayers.
  • Acting for Cantor Fitzgerald in relation to a VAT dispute on certain purchases of emissions allowances.
  • Acting for the BT Pension Fund Trustees, and around 100 other pension funds, in the foreign income dividend and tax credit group litigation, which resulted in the first judgment of the European Court following the Brexit referendum 2016.
  • Acting for Avon Cosmetics Limited in the CJEU in a case concerning the VAT regime for direct selling companies.
  • Acting for the taxpayers in their appeal to the Court of Appeal in Samarkand & Proteus v HMRC [2017] EWCA Civ 77, which is the latest leading case relating to sale and leaseback film scheme losses.
  • Acting for British Coal and 30 of the UK's largest employer pension funds including Diageo, BAE Systems and John Lewis Partnership in a dispute concerning HMRC's application of a withholding tax. A reference has been made to the CJEU.
  • Acting for UBS AG in the Supreme Court in UBS AG v HMRC [2016] UKSC 13 concerning its employee incentive arrangements.
  • Acting for the taxpayer in the Upper Tribunal in HMRC v Raymond Tooth [2018] UKUT 38 (TCC) in which we successfully argued that HMRC could not rely on extended discovery assessment time limits.