Tax

Our tax disputes team is led by Fiona Walkinshaw, previously a partner and head of corporate tax litigation at Deloitte.

The team advises businesses and individuals on all aspects of the tax enquiry process from instigation of the enquiry by HMRC through to its ultimate resolution, whether by negotiation, facilitated dispute resolution (ADR) or litigation. It also deals with tax related claims outside of the enquiry process and has litigated at all levels of the tribunals and courts including the CJEU in Luxembourg.

The team has particular experience of:

  • Negotiating settlements with HMRC on single or multiple tax issues
  • Devising pre-litigation strategies
  • Taking single appeals to Tribunal and beyond
  • Coordinating and running group actions for taxpayers with similar issues (both domestic courts and claims before the CJEU)
  • Dealing with Accelerated Payment Notices and Follower Notices
  • Judicial Review on points of process/HMRC decision making
  • Disclosure/Discovery issues and formal requests for information

The team works across all sectors and has handled disputes involving a wide range of taxes including corporation tax, capital gains tax, income tax and NICs, stamp duty, inheritance tax and VAT; also reliefs such as capital allowances and R and D credits.

Examples of previous cases include:
  • TDS and Ladbrokes Group v HMRC 2015 UKFTT 582
  • Barclays and Dreelan v HMRC 2015 EWHC 2878 Ch
  • Biffa Jersey Ltd v HMRC 2014 UKFTT 982
  • Howden Joinery v HMRC 2014 UKFTT 257
  • Icebreaker 2 (Hawksbridge) LLP v HMRC 2014 UKFTT 416 TC
  • Icebreaker 1 LLP v HMRC 2011 STC 1078
  • Angus Monro v HMRC 2007 EWHC 114 Ch
  • Compass Contract Services v HMRC 2006 EWCA Civ. 730

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