Tax & HMRC disputes
Balancing disclosure obligations with strategic negotiation.
We act for corporates, directors, and HNWIs facing civil and criminal tax exposure, assisting with voluntary disclosures, tribunal advocacy, and defence of punitive assessments.
Key workstreams
- HMRC Civil Tax Investigations and discovery assessments
- Contractual Disclosure Facility (CDF) and Code of Practice 9 matters
- Tax Tribunals – FTT and UT advocacy with specialist counsel
- VAT assessments, input tax disputes, and supply chain fraud investigations
- Covid-19 scheme audits and director personal liability notices
- Tax avoidance scheme investigations and promoter penalties
Approach
We perform parallel fact-finding, privilege reviews, and settlement modelling so clients understand the litigation window versus cooperative pathways. Our team coordinates with accountants to map evidential gaps before initial HMRC interviews.
Illustrative outcomes
| Matter | Action | Result |
|---|---|---|
| CDF disclosure for logistics group | Managed forensic review, drafted disclosure report | Settled with staged payment schedule, no prosecution |
| VAT assessment challenge | Filed FTT appeal and expert evidence | Assessment reduced by 70% |
| Personal liability notice | Negotiated withdrawal following director interviews | Notice rescinded, reputational risk mitigated |
Clients
We represent corporates, entrepreneurs, trustees, and advisors who require a cohesive strategy between legal counsel and tax specialists. Matters often involve sensitive disclosures or parallel criminal exposure.
Tax disputes are fact-sensitive; this overview should not be relied on without seeking tailored advice. Engagement is subject to conflict checks and anti-money laundering due diligence.