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Tax disputes


Meet the team

Our London tax disputes team has impressive breadth and considerable experience in advising on the full range of tax-related disputes throughout the UK and worldwide. Working alongside our lawyers across Europe, the United States, Canada, Latin America, Australia and Africa, we handle both domestic and cross-border litigation for a number of prominent financial institutions and corporations.

“I like their accessibility, the concision and commerciality of their advice, and their speed of execution.” Chambers UK, 2015

Working in close co-operation with our asset finance and litigation and dispute resolution lawyers, as well as with lawyers across our key industry sectors, we can provide a full-service approach to every dispute. Clients will also benefit from our in-depth commercial and legal knowledge of their industry, particularly: financial institutions; energy; transport; technology and innovation; and life sciences and healthcare.

We deliver

  • Extensive experience in audits and investigations carried out by the UK tax authorities and authorities around the world.
  • Experience in handling tax-based litigation of all types and at all levels; you will find us to be flexible, robust and determined on your behalf.
  • Industry knowledge, enabling us to provide the additional benefit to clients of a thorough understanding of the industry sector and commercial context of the relevant facts and law; this strengthens our ability to negotiate intelligently, and if resolution is not achieved, enables us to judge the most effective and appropriate litigation strategy.

Our areas of work include

  • alternative dispute resolution of tax matters
  • appeals
  • judicial review
  • mainstream litigation
  • risk management (including on tax structured transactions)
  • settlement with tax authorities
  • tax audits and investigations.

Our recent work

  • Advising the taxpayer, a special purpose leasing company within Lloyds Banking Group, and winning at the first instance hearing in the First-tier Tribunal. This was the first taxpayer victory in a “main purpose” case for over 30 years and the case will have an impact across the wider tax world, as there are very few decisions on the application of “main purpose” tests.
  • Advising HSBC in litigation concerning the compatibility of the UK's SDRT regime for American depositary receipts (ADR) with EU law. This case has led not only to significant repayments for HSBC but also to a number of corporate taxpayers. HMRC have also had to change its interpretation of the law to comply with the Judgment.