Herbert Smith Freehills Kramer LLP hosts a wealth of contentious tax expertise, with its experience spanning disputes regarding personal tax, employment tax, indirect tax, direct business tax, international tax and commercial tax. Its team is knowledgeable of an array on sectors, notably energy, financial services, real estate and TMT. Nick Clayton is responsible for overseeing the practice and has ample experience handling large tax disputes for UHNWIs, financial institutions and corporates. Michael Hunt is a standout member of the team and is experienced at handling contentious matters relating to worker status and the tax implications of internationally mobile employees. Dawen Gao is also a highly regarded member of the team and brings extensive knowledge of tax disputes across the banking, insurance, energy, real estate and TMT sectors to the practice.
Tax litigation and investigations in London
Herbert Smith Freehills Kramer LLP
Responsables de la pratique:
Nick Clayton
Autres avocats clés:
Michael Hunt; Dawen Gao; Avi Haffner
Les références
‘The HSF dispute resolution team are a dedicated client facing team with excellent attention to detail. We have worked with the team for more than 10 years, and they have seamlessly guided us through the litigation process.’
‘Highly skilled and technically brilliant.’
‘Michael Hunt is a safe pair of hands.’
Principaux clients
Orsted
Bernie Ecclestone
Neptune Energy
Moorfield
PacifiCorp Inc. (a Berkshire Hathaway company)
Berkeley Group
Virgin Media O2
Principaux dossiers
- Acting for Ørsted in its successful appeal in the Court of Appeal on the availability of capital allowances on offshore windfarm development costs.
- Acted for Bernie Ecclestone in civil and criminal proceedings brought by HMRC and CPS in respect of investigations into Mr Ecclestone’s UK tax affairs.
- Acting for the Berkeley Group on an appeal to the Upper Tribunal (Tax and Chancery Chamber) against HMRC’s assessment of a Berkeley subsidiary to stamp duty land tax (« SDLT ») in respect of an intragroup transfer of land.
Joseph Hage Aaronson & Bremen LLP
Boutique tax firm Joseph Hage Aaronson & Bremen LLP is respected in the market for its ability to handle large tax disputes and group litigation in the First-tier Tribunal, Upper Tribunal, High Court, Court of Appeal, UK Supreme Court and CJEU. The team is spearheaded by Graham Aaronson KC, who is relied on by a full spectrum of taxpayers, from industrial corporations and financial service businesses to entrepreneurs and HNWIs; and Michael Anderson, who has established experience in tax litigation at all levels of the UK’s Tax Tribunals, domestic courts and European Court. Iain MacWhannell enjoys a market leading presence in cases involving HMRC’s investigative powers, tax fraud, tax evasion and tax abuse. Daniel Margolin KC is well versed in HMRC litigation, and Helen McGhee has strong credentials in COP9 investigations. Simon Whitehead retired from the firm in January 2025.
Responsables de la pratique:
Graham Aaronson; Michael Anderson
Autres avocats clés:
Iain MacWhannell; Paul Farmer; Daniel Margolin KC; Helen McGhee
Principaux clients
British American Tobacco Plc
Universal Music
Evonik
FCE Bank Plc
‘The VAT Umbrella Appeals’
“Post-Prudential” Closure Notice Appeals and Closure Notice Applications (PPCN) Group Litigation
The Evonik group of companies (Evonik UK Holdings Limited & Others)
Impact Contracting Solutions
Ducas Ltd
Enix Ltd
FL Capital Ltd
The Kittel Class Action
AXA Insurance UK Plc
AXA Insurance Plc
Redevco Properties UK Limited
Dandara Group
Principaux dossiers
- Acting as the lead solicitors in the Franked Investment Income (“FII”) GLO.
- Representing over 24,000 Mini Umbrella Companies in their appeals to the Tax Tribunal against assessments to VAT, National Insurance Contributions, and VAT de-registration.
- Acting on behalf of over 170 investment funds and other entities in the financial services sector in respect of disputes arising in over 1,000 accounting periods.
Slaughter and May
Possessing ‘strategic thinking and tactical nous’, Slaughter and May is routinely at the head of significant issues in the market, notably those pertaining to partnership tax, the UK-US double tax treaty, and VAT groups. Richard Jeens and Dominic Robertson form the duo that leads the team. Jeens has a high level of experience in multijurisdictional mandates which overlap practice areas. Robertson is noted for his capabilities in statutory interpretation and cross-border matters. Mike Lane brings in-depth knowledge of financial services disputes and international tax treaty matters to the group. Ewan Brown has notable specialism in financial services tax litigation and partnership tax issues.
Responsables de la pratique:
Richard Jeens; Dominic Robertson
Autres avocats clés:
Ewan Brown; Mike Lane
Les références
‘Really excellent – strong at every level and they really put their clients first. A wonderful and well-deserved reputation.’
‘Dominic Robertson is just so bright. Really pragmatic and gets to the heart of the issue. Mike Lane is extremely experienced and so on top of matters – first-rate!’
‘Always do an excellent job in supporting the business. Very thorough and supportive. Able to give strong technical advice. Billing is clear and timely. The team work well together and with other advisors when required.’
Principaux clients
Barclays
BlueCrest Capital Management
Bupa
GE Aerospace
GSK
ITV
Vodafone
Principaux dossiers
- Advised Barclays on a £300m HMRC dispute regarding overseas companies joining UK VAT groups.
- Advised BlueCrest Capital Management on Court of Appeal litigation concerning LLP members’ tax status.
- Advised GE Aerospace on a £190m Court of Appeal dispute with HMRC concerning interpretation of the US-UK double tax treaty.
Ashurst
The tax disputes practice at Ashurst is recognised for its ability to handle VAT litigation, indirect tax, employment taxes and EU State Aid and other EU tax-related contentious matters. The team routinely undertakes work within the firm’s priority industry sectors, notably financial institutions, funds, natural resources, and infrastructure. Nicholas Gardner heads up the group and has experience in tax litigation before all levels of the UK courts. Paul Miller‘s expertise has a notable emphasis on the financial services industry. Sara Mardell‘s strengths lie in litigation against HMRC before the tax tribunals and higher courts.
Responsables de la pratique:
Nicholas Gardner
Autres avocats clés:
Sara Mardell; Paul Miller; Beth Sercombe
Les références
‘Sara Mardell is a brilliant partner – really technically bright, fantastic to work with and just so able. Nick Gardner has excellent technical experience.’
‘It is the competency and customer care that makes this practice unique. They are excellent communicators, simplifying complex legislation, and they actively engage with us on a regular basis. They are also supportive in terms of budgeting and tracking costs and explaining charges.’
‘They are extremely personable and operate very much as part of a team, completely aligned with their client requirements. In particular, Sara Mardell is a very down to earth and an exceptional communicator and facilitator, bringing together stakeholders and providing clear and concise summaries of what is required.’
Principaux clients
Imperial Brands PLC
Odfjell Technology (UK) Limited (Odfjell)
Hastings Insurance Services Limited
Odfjell Technology (UK) Limited (Odfjell)
Syngenta Holdings Limited
Wood Group Engineering (North Sea) Limited
Government of Jersey
Rockhopper Exploration PLC
Principaux dossiers
- Filed an application with the CJEU on behalf of Imperial Brands PLC for the annulment of a decision by the EC.
- Advising Odfjell Drilling in relation to a potential employer NIC assessment for periods from 2003 to 2014.
- Acting for Hastings Insurance Services Limited in relation to an appeal in the First-tier Tax Tribunal.
Baker McKenzie
Clients praise the contentious tax team at Baker McKenzie for ‘always looking for solutions to tax disputes with HMRC’. The group’s expertise is particularly sought out by clients with disputes in the financial institutions, healthcare, TMT and FMCG sectors. Co-heads David Jamieson and Jessica Eden both take responsibility for steering the practice. Jamieson is a reputed VAT lawyer and fields a wealth of knowledge in VAT disputes stemming from the financial services, telecoms and e-commerce sectors. Eden provides the corporate tax expertise, seeing her frequently advise on HMRC investigations into international structures. Jukka Karjalainen leads on the transfer pricing front.
Responsables de la pratique:
David Jamieson; Jessica Eden
Autres avocats clés:
Jukka Karjalainen; Salli McElligott; Mark Delaney; Naoko Uehara
Les références
‘Very proactive and supportive – always looking for solutions to tax disputes with HMRC. the team understand our business well and are readily available to assist when needed’
‘Jess Eden – Jess is more in the background, but she knows our business well and is always there if needed to give another opinion or give insights on strategy. Very professional and technically competent. very pleased to have her as part of the team. Jukka Karjalainen – we have only been working with Jukka for a short time, but he has become a valuable additional resource to us as clients.’
‘The Bakers team is very deep, and they have people with various specialities – technical, procedural, modelling etc. They are very proactive and provide great client service. Great insights and ideas.’
Principaux clients
Electronic Arts
European Tyre Enterprise Limited
JP Morgan
MDU (Medical Defence Union Limited)
Refinitiv
Takeda
Thames Television
The Prudential Assurance Company Limited
Thomson Reuters
UK Power Networks
Principaux dossiers
- Advised the Kwik-Fit Group on a dispute with HMRC over interest deductibility (unallowable purpose).
- Represented Prudential in the Court of Appeal in January 2024 on the VAT treatment of investment management services.
- Acted for Thomson Reuters Corporation in a Judicial Review of HMRC’s decision to issue Diverted Profits Tax Notices in contravention of an Advanced Pricing Agreement.
Bryan Cave Leighton Paisner
Harnessing ‘deep litigation experience’, Bryan Cave Leighton Paisner is able to advise on disputes across a range of direct and indirect taxes. The group has developed particular expertise in corporate tax disputes, VAT disputes and SDLT disputes. The practice is jointly headed by Elizabeth Bradley and Kate Ison, whose expertise in HMRC enquiries and criminal investigations is an asset to the team. Alan Sinyor is a standout feature of the team and heads the firm’s indirect tax offering, with specialist knowledge in contentious VAT and customs duties matters.
Responsables de la pratique:
Elizabeth Bradley; Kate Ison
Autres avocats clés:
Alan Sinyor; Kyle O’Sullivan; Maite Aguirre Quiñonero
Les références
‘Highly collaborative and engaged.’
‘Deep litigation experience and highly diligent. Stand out partners include Kate Ison. Stand out associates include Maite Aguirre Quiñonero.’
‘Deep industry knowledge – wouldn’t want to work with anyone else within banking litigation in the UK.’
Principaux clients
Brindleyplace Holding Sarl
Principaux dossiers
- Advising Lycamobile UK on a VAT dispute with HMRC over the VAT treatment of certain of its telecom products.
- Advising Brindleyplace Holding Sarl on a SDLT appeal heard by the First-Tier Tribunal in July 2024.
DLA Piper
DLA Piper prides itself on its tax disputes capabilities, seeing it acting before the courts on tax test cases, as well as supporting clients undergoing transfer pricing investigations regarding their global business models. Jason Collins takes charge of leading the team and excels in disputes involving transfer pricing, corporation tax, diverted profits tax, ORIP, and employment taxes. Stuart Walsh is also a key name in the group for anything indirect tax related. Randall Fox leads on the transfer pricing work. Clara Boyd is a key contact for large corporates facing VAT and other indirect tax disputes with HMRC, and Lauren Redhead is the go-to for corporation tax disputes against HMRC.
Responsables de la pratique:
Jason Collins
Autres avocats clés:
Randall Fox; Lauren Redhead; Richard Woolich; Clara Boyd; Stuart Walsh
Les références
‘Blue chip practice with a disputes team second to none.’
‘Jason Collins has been at the top of the tree for a while now. Stuart Walsh knows everything there is to know about VAT.’
Principaux clients
CCLA Investment Management Limited
JTI Acquisitions Company (2011) Limited, Komatsu America Corp
NatWest Markets plc (formerly RBS plc) (“NWM plc”)
Mid Ulster District Council
Principaux dossiers
- Represented CCLA in its VAT appeal before the FTT.
- Acting for JTI Acquisitions Company (2011) Limited in an appeal to the Court of Appeal against a decision of the Upper Tribunal.
- Acting for NatWest Markets plc on a dispute arising from missing traders in its carbon credit supply chains defaulting on VAT due to HMRC.
Ernst & Young LLP
Ernst & Young LLP‘s tax disputes team is familiar with complex disputes before the FTT up to the supreme court, as well as with public law judicial review cases. Its clients range from UHNWIs to large corporates, especially those from the oil and gas and energy sectors. The capable quartet jointly leading the group is formed of Boaz Goren, whose strengths lie in tax litigation and arbitration; Mitchell Moss, who heads the indirect tax offering; Julian Balson, who excels in VAT, customs and excise duty fraud litigation and investigations; and Elyse Waller, who is the go-to for direct tax disputes involving corporate taxpayers. Dan White is also a name to note.
Responsables de la pratique:
Boaz Goren; Mitchell Moss; Julian Balson; Elyse Waller
Autres avocats clés:
Dan White
Principaux clients
Biffa Plc
Muller UK & Ireland Group LLP and other companies
Dolphin Drilling Limited
ThyssenKrupp Materials (UK) Ltd
Bryan Robson Ltd
The Mersey Docks and Harbour Company
Align Group
Nexans
Principaux dossiers
- Acted for Biffa plc in respect of a £100m Landfill Tax enquiry into “qualifying fines” and the “Loss on Ignition” (LOI) testing regime within Excise Notice LFT1.
- Represented Muller UK & Ireland Group LLP in its appeal following HMRC’s decision to disallow an amortisation of acquisition costs.
- Acted for Thyssenkrup Materials (UK) Ltd in a £8.9m dispute with HMRC in relation to the interpretation of the law on customs special procedures.
Fieldfisher
Fieldfisher‘s ‘excellent litigation experience’ in the contentious tax domain spans tax disclosures, enquiries, lobbying, ADR, tribunal litigation, appeals, judicial reviews, restitution and rectification claims and EU litigation. George Gillham sits at the head of the practice and is highly regarded for his skills in managing tax enquiries, disclosures and litigation following his time as a former IR tax inspector. Philippe Freund is routinely instructed on international tax enquiries, and Siobhan Gillespie regularly gets involved in disputes involving both direct and indirect taxes. Matthew Sharp departed to Brown Rudnick LLP in March 2024
Responsables de la pratique:
George Gillham
Autres avocats clés:
Philippe Freund; Siobhan Gillespie; Christopher Kientzler
Les références
‘Great technical ability, combined with very good client skills.’
‘George Gillham is a pleasure to be instructed by – amiable and calm.’
‘Excellent litigation experience and strategic and tactical insight.’
Principaux dossiers
KPMG Law
KPMG Law‘s wide-ranging tax disputes and investigations practice encompasses VAT, corporation tax, customs and excise duties, judicial review and income tax expertise. Angela Savin and Matthew Fleming jointly take on the role of practice heads. Savin specialises in the direct tax work and particularly excels in advising taxpayers in ‘main purpose’ disputes with HMRC. Fleming is the go-to for indirect taxes and is especially knowledgeable of VAT, customs duty, excise, gaming duty, and environmental taxes. Colette Van Zyl is an asset to the practice and is well versed in complex VAT disputes. Lee Ellis is also an active member of the group.
Responsables de la pratique:
Angela Savin; Matthew Fleming
Autres avocats clés:
Colette van Zyl; Lee Ellis
Principaux clients
Altrad Services Limited
David Lloyd
DHL Air Ltd
GAP Group Limited
Genesis Cancer Care Limited
Holland & Barrett
HSBC Bank plc
Knot Builders Ltd
Kopparberg/Cider of Sweden
Liverpool University NHS Foundation Trust
PD Ports Services Limited
Robert Wiseman and Sons Limited (client since 2015)
Sims Group UK Ltd
Sonder Europe Limited
Tapi Carpets and Floors Limited
United Grand Lodge of England
Principaux dossiers
- Representing DHL Air Ltd in a case heard before the Upper Tribunal following a precedent-setting win before the First-tier Tribunal in a dispute over End Use authorisations.
- Representing Knot Builders Ltd in opposing a statutory levy charged by the Construction Industry Training Board.
- Acting for Altrad Services Limited and Robert Wiseman and Sons Limited against the tax treatment of historic lease and leaseback transactions.
Macfarlanes LLP
The ‘world class’ tax litigation practice at Macfarlanes LLP is well-equipped to advise on a full spectrum of contentious tax matters, including tax risk management, judicial review, transfer pricing, settlements, insured tax risks, tax administration and private client tax matters. Gideon Sanitt leads the team with a ‘wealth of experience of HMRC behaviour and negotiation’. Sophie Rhind is a key feature of the team and brings expertise in judicial review matters.
Responsables de la pratique:
Gideon Sanitt
Autres avocats clés:
Sebastian Prichard Jones; Sophie Rhind; Jackelyn West; Victoria Braid
Les références
‘Really strong – a great mix of expertise.’
‘Gideon Sanitt, great to work with, deep knowledge.’
‘Gideon Sanitt provides practical, user-friendly advice with a wealth of experience of HMRC behaviour and negotiation.’
Principaux clients
Royal Mail Group Limited (Royal Mail)
CDC Administration LLP
HFFX LLP and individual members
Principaux dossiers
- Advising Royal Mail in the group litigation brought against it involving circa 300 Claimants who argue that postal services supplied to them by Royal Mail from the 1970s onwards were not exempt from VAT.
- Advising HFFX LLP and a number of its individual members on a dispute with HMRC regarding its Capital Allocation Plan.
- Advising the appellants of CDC Administration in an appeal that reached the Supreme Court in a case relating to investments in Enterprise Zones.
PwC LLP
PwC LLP‘s well established client base includes FTSE 100 groups, large multinationals, private businesses, and high-net-worth individuals. Mark Whitehouse and David Anderson jointly oversee the practice. Whitehouse draws on extensive contentious tax knowledge, notably in tax planning challenges, corporate tax appeals and international transfer pricing disputes. Anderson is a dedicated indirect tax disputes lawyer, with exceptional VAT expertise. Peter Johnson excels in disputes involving international corporate tax and financial structures.
Responsables de la pratique:
Mark Whitehouse; David Anderson
Autres avocats clés:
Peter Johnson; Victor Cramer
Les références
‘The team at PWC are very professional in their approach and their knowledge and technical expertise of the subject matter (case) is excellent. Their thinking behind strategy to the is also very good. The team I work with are good at taking the technical legal argument and translating to layman terms for client interaction.’
‘Phenomenal breadth of knowledge, the guys are at the very top of their game. They’re patient, diligent and incredibly thorough. We count ourselves lucky to have them in our corner.’
‘I have worked with David Anderson for a number of years. He and his team were responsive and efficient.’
Principaux clients
Hippodrome Casino Limited
Boehringer Ingelheim Limited
TalkTalk Telecom Limited
St Patrick’s International College Limited
Principaux dossiers
- Representing Hippodrome Casino Ltd in a matter relating to the VAT “use” of the building.
- Acting for TalkTalk in its UT appeal over the interpretation of historic VAT legislation for prompt payment discounts.
- Representing Boehringer Ingelheim in litigation over HMRC’s rejection of their claims for repayment of output tax on supplies to the NHS,
Quinn Emanuel Urquhart & Sullivan, LLP
Distinguished by its ‘unrivaled experience of high profile and high value tax litigation matters’, Quinn Emanuel Urquhart & Sullivan, LLP is a popular choice for ultra-high-net-worth tax disputes. The group is also noted for its tax knowledge in the media sector. Highly regarded Liesl Fichardt leads and is regularly called upon by corporates, multinationals and HNWIs to handle tax disputes. Epaminontas Triantafilou is a point of reference for his experience in international arbitration. Justin Michaelson also draws on significant experience in international commercial disputes and is regularly before arbitral tribunals. Emily Au is experienced in regulatory enquiries, investigations, voluntary disclosures and ADR.
Responsables de la pratique:
Liesl Fichardt
Autres avocats clés:
Epaminontas Triantafilou; Justin Michaelson; Emily Au; Matthew Tse
Les références
‘Liesl Fichardt leads a highly competent, able team capable of and specialising in dealing with multiple litigants. The team also has the ability to deal with technical tax questions and knows its way through the thickets of the procedural jungle.’
‘Liesl Fichardt has particular people skills. She is ably assisted by Matthew Tse and Emily Au who seem to be indefatigable.’
‘The team has unrivalled experience of high profile and high value tax litigation matters. They provide concise and pragmatic advice, backed by experience, intellect and a drive to do the best by their clients.’
Principaux clients
Unite Group
Kellas Midstream Limited
Bauer Media
Principaux dossiers
- Acting for Unite Group in multiple VAT refund claims against HMRC.
- Acting for an energy infrastructure company that acquired multi-million-pound energy assets in the North Sea.
- Advising Bauer Media on a variety of employment tax-related issues.
RPC
The tax disputes and investigations group at RPC is routinely instructed in large tax litigation cases, group litigations and group association cases. Its expertise also extends to HMRC investigations for HNWIs and judicial review proceedings for both corporates and individuals. Adam Craggs sits at the head of the practice and draws on extensive direct and indirect tax disputes resolution expertise, notably in HMRC’s ADR process. Michelle Sloane is a highly regarded member of the team for her knowledge of VAT and customs and excise duty disputes.
Responsables de la pratique:
Adam Craggs
Autres avocats clés:
Michelle Sloane
Les références
‘Adam was incredibly empathetic to our case and as reassuring as he could be given the circumstances. I haven’t any experience of anyone to compare to, but I would not want to try anyone else either.’
‘The team are very organised and were complimented on their excellent bundles in a recent hearing.’
‘Adam Craggs is approachable and great to work with. He responds quickly to any queries and has a calm and pragmatic approach to issues as they arise.’
Principaux clients
Universal Cycles
Newcastle United Football Club
Clipperton & Lloyd
Local Fuel Limited
Gourmet Classic Limited
Principaux dossiers
- Acted for a private individual in a £13m+ dispute with HMRC.
- Acting for Newcastle United Football Club (NUFC) in its multi-faceted dispute with HMRC stemming from an enquiry into agents’ fees.
- Acted for Gourmet Classic Limited in its successful appeals against HMRC’s excise duty assessments concerning cooking alcohol products.
Simmons & Simmons
Lauded for its ‘deep experience of handling the most complex disputes with HMRC’, Simmons & Simmons is best known for its work representing clients across the financial services, asset management and environmental sectors in tax litigation. Heather Rowlands takes on the role of practice head and is praised for her ‘extremely broad experience, particularly in VAT’. Craig Kirkham-Wilson is a standout feature of the team for his work in tax tribunal advocacy, criminal and civil investigations and mediations.
Responsables de la pratique:
Heather Rowlands
Autres avocats clés:
Monique Van Herksen; Craig Kirkham-Wilson; Katie Oliver; Darren Oswick
Les références
‘Really excellent partners and associates. Very technical, lots of practical knowledge and great to work with.’
‘Heather Rowlands has extremely broad experience, particularly in VAT. Katie Oliver is a very bright and hard-working senior associate. One to watch.’
‘This is a truly excellent team. In depth expertise, excellent resourcing and a great collaborative spirit.’
‘The team at Simmons offer excellent and really hard-working client service and have one of the best litigation practices in London, matching the magic circle firms.’
‘Darren Oswick, Heather Rowlands, Craig Kirkham-Wilson and Katie Oliver are all superb. Heather in particular is a standout partner in terms of her diligence and attention to detail.’
‘One of the best tax litigation teams about. Deep experience of handling the most complex disputes with HMRC. Absolutely fantastic client care.’
‘Heather Rowlands is extremely capable and intelligent and wears her brilliance lightly. She is an absolute pleasure to work with. Excellent judgment at all times. Real hard work and creative solutions. She is the best. Katie Oliver is becoming a very competent and able lawyer. ’
‘Genuinely one of, if not, the best tax litigation teams in the market, especially on the private client side.’
Principaux clients
Willis Towers Watson
Christopher Rokos (principal of Rokos Capital Management)
Augean Limited
Davidson Kempner Capital Management
The Saint-Gobain group
RNIB, the Royal National Institute of Blind People (acting pro bono)
Principaux dossiers
- Acting for Burlington Loan Management DAC (Davidson Kempner Capital Management) in a multi-million-pound tax treaty dispute.
- Acting for Augean in ‘test case’ appeals relating to the landfill tax liability of waste from numerous industrial processes.
- Acting for multiple asset managers and hedge funds with limited liability partnership structures in disputes with HMRC regarding the application of the ‘salaried member rules’.
A&O Shearman
The contentious tax offering at A&O Shearman is praised for its thoroughness, covering HMRC negotiations and settlements, tribunal and court proceedings, commercial litigation proceedings and tax investigations. Jointly overseeing the practice is Christopher Harrison, who is well versed in tax investigations, administrative controversies and tax litigation; and Charles Yorke, who is routinely instructed by financial institutions, major oil companies and infrastructure groups. Eve Giles brings significant experience in financial crime investigations involving tax to the practice. Lydia Challen provides a well-rounded understanding of contentious issues regarding corporate tax and structuring matters.
Responsables de la pratique:
Christopher Harrison; Charles Yorke
Autres avocats clés:
Eve Giles; Lydia Challen
Les références
‘Committed, hardworking team’
‘Highly engaged in the case with excellent technical knowledge’
‘Very diligent and knowledgeable, robust and clear in their articulation of advocacy positions.’
Principaux clients
Investec Bank plc
Lloyds Banking Group
Principaux dossiers
Eversheds Sutherland (International) LLP
The tax disputes practice at Eversheds Sutherland (International) LLP offers a breadth of expertise spanning VAT, customs duties and tax investigations by UK and international tax authorities. Robert Waterson is in charge of leading the practice and brings experience in customs disputes and criminal investigations. Ben Jones is a key figure in the team and is skilled in both contentious and non-contentious tax matters. Edward Griffiths is a name to note for his indirect tax expertise, notably VAT, IPT and customs duties matters.
Responsables de la pratique:
Robert Waterson
Autres avocats clés:
Edward Griffiths; Ben Jones
Les références
‘An excellent team from Eversheds on which Ed Griffiths was the point man. Ed and the team provided excellent, pragmatic advice and counsel on a pragmatic basis. Efficient and responsive to requests/questions.’
‘All the team members (Ed, Robert & Ben) are friendly, efficient, knowledgeable and pragmatic. Always responsive and efficient. They always worked together and in our best interests to deliver value. A great pleasure to work with.’
‘Very responsive and takes a commercial and pragmatic approach.’
Principaux clients
Universal Cycles Limited
Frasers Group Plc
Principaux dossiers
Hogan Lovells International LLP
Hogan Lovells International LLP draws on expertise in tax litigation, HMRC enquiries and tax-led internal investigations concerning a variety of taxes, notably corporation tax, employment tax, transfer pricing, VAT, customs duty, excise duties and personal tax. Rupert Shiers heads the team and is praised by clients for being ‘extremely responsive and collaborative’. Suzanne Hill is also a name to note from the team.
Responsables de la pratique:
Rupert Shiers
Autres avocats clés:
Suzanne Hill; James Hotchkiss
Les références
‘Rupert Shiers – I found Rupert extremely responsive and collaborative. He was easy to work with and did a very good job of imparting technical content in a comprehensible manner.’
‘Rupert and James are very helpful, organised, and attuned to business needs. This means that in turn, their advice is pragmatic as well as technically accurate.’
‘A very competent and proactive team of multidisciplined counsel. The firm’s use of technology was particularly noteworthy; utilising their AI systems, they were able to effectively process vast amounts of data, mining it for the relevant and pertinent information required for the matter.’
‘The knowledge and effective case management were excellent, giving you confidence that the complex matter was being well managed by the firm.’
‘They have a very strong knowledge of the tax laws of the various jurisdictions we have worked with them. They simplify the explanation of an issue, so the client has the solid understanding of if any risk they made face. They work very with the tax authorities, very good contacts within the tax departments and are able to negotiate favourable terms when closing various controversies for us.’
Principaux clients
Bank of New York Mellon
British-American Tobacco
Dentists’ Provident Society
eBay
Eurasian Resources Group
General Reinsurance
Groupon
Parker Hannifin
Reach plc
TripAdvisor
Principaux dossiers
- Advised Reach plc on a high sensitivity high value enquiry into corporation tax treatment of “phone hacking” expenses.
- Advised a global fund manager on complex employment tax disclosures and associated commercial issues.
- Advised Eurasian Natural Resources Corporation Limited on a high value VAT input tax investigation.
Kingsley Napley LLP
Drawing on the firm’s wider expertise in dispute resolution, criminal ligation and private client, Kingsley Napley LLP creates a formidable tax disputes and investigations offering. Waqar Shah is responsible for leading the practice and ‘is particularly well versed in matters concerning VAT disputes, or tax investigations’. David Sleight is an active member of the team and also a go-to for tax fraud related issues. Krishna Mahajan is a highly appreciated member of the team for her knowledge of tax fraud, voluntary and promoted disclosure and indirect tax.
Responsables de la pratique:
Waqar Shah
Autres avocats clés:
David Sleight; Krishna Mahajan
Les références
‘Kingsley Napley (Tax Litigation and investigation) is a practice capable of dealing with complicated, time-consuming or even sometimes, potentially life-changing tax matters.’
‘Being a local law firm, Kingsley Napley is unique by having a strong capacity understanding and dealing with its international clients.’
‘Waqar Shah (Partner) has showed strong accountability, responsibility throughout my case.
Principaux dossiers
Norton Rose Fulbright
Norton Rose Fulbright is well versed in tax disputes before the UK courts and tribunals, as well as in tax authority investigations and negotiations with tax authorities. Dominic Stuttaford and Matthew Hodkin are the duo who oversee the team. Stuttaford is the global head of tax and is regularly litigating before all levels of the UK courts, tribunals and ECJ. Hodkin brings extensive knowledge of the energy, infrastructure and transport sectors to the practice. Ruth Cowley is also an active member of the team.
Responsables de la pratique:
Dominic Stuttaford; Matthew Hodkin
Autres avocats clés:
Ruth Cowley
Les références
‘Matt Hodkin – a first-class tax partner. His technical tax knowledge is unrivalled, as well as his ability to translate the legislation for non-tax colleagues and clients. He understands the client position, what is important to us and any commercial considerations.’
Principaux clients
HSBC
Royal Bank of Canada
Takeda
Principaux dossiers
- Acting for RBC in successfully defending an appeal by HMRC to the UK Supreme Court in relation to a dispute with HMRC concerning the taxation of payments relating to North Sea Oil production.
- Acting for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.
- Acting for HSBC in successfully defending two related complex group action fraud claims seeking damages of around £1.7bn.
Skadden, Arps, Slate, Meagher & Flom (UK) LLP
The tax controversy practice at Skadden, Arps, Slate, Meagher & Flom (UK) LLP is well versed in an array on cross-border tax controversies, including transfer pricing and CA matters, as well as in disputes arising from global and regional business transactions. The practice is jointly headed by James Anderson, who is an expert in the energy sector, and Patrick O’Gara, who was welcomed to the firm in November 2024 from Baker McKenzie LLP. Kate Davies KC is also a key name in the team and is lauded for her arbitration expertise.
Responsables de la pratique:
James Anderson; Patrick O’Gara
Autres avocats clés:
Kate Davies KC
Les références
‘It is the people, rather than the practice, in my opinion.’
‘James Anderson (partner) – encyclopedic knowledge of tax legislation and case law, freakish responsiveness, unambiguous and succinct advice that gets to the heart of the matter expeditiously. James is an industry icon, unsurpassed in his field.’
‘Excellent tax team.’
Principaux dossiers
- Advising a global diversified alternative asset management firm in MAP and APA applications resulting from HMRC enquiries across a range of UK tax issues.
- Advising a biopharmaceutical company on matters relating to the progression of its High Risk Corporate Programme, which involved a long-running enquiry by HMRC into various IP and supply chain transactions worth over a combined $10 billion.
- Advising this client on potential claims under a tax indemnity. These claims relate to the potential imposition of Saudi taxes on previously-executed corporate transactions.
Stewarts Law LLP
Considered by clients as ‘one of the best tax litigation teams around’, Stewarts Law LLP is regularly involved in disputes with HMRC about primary tax liability, as well as disputes with commercial parties to claim back losses. David Pickstone sits at the head of the practice and specialises in direct tax, environmental taxes and commercial tax litigation. Giles Salmond is well known for VAT, customs duties and other indirect tax disputes against HMRC. Matthew Greene is experienced in litigation before the tax tribunal and higher courts, as well as in negotiating settlements with HMRC.
Responsables de la pratique:
David Pickstone
Autres avocats clés:
Matthew Greene; Anastasia Nourescu; Giles Salmond; Adam Jacobs; James Le Gallais
Les références
‘Excellent strength in depth across all areas of tax’
‘David Pickstone – versatility and strategic and commercial insight and awareness’
‘I regard them as one of the best tax litigation teams around. I have recommended that clients use them, especially when they have related commercial issues, because they can handle the all-round needs of a client.’
Principaux clients
Singleton Birch Limited and FCC Recycling UK Limited
Principaux dossiers
- Acting for Singleton Birch Limited and FCC Recycling UK Limited, two waste management companies, in a tribunal appeal against a £10m assessment to landfill tax.
Bark&co
Bark&co is chosen by clients for its ability to ‘deal with investigations and pre-charge matters as well as disputes’. The group particularly excels in criminal tax fraud and civil tax disputes involving VAT and excise duty. Giles Bark-Jones leads the group which benefits from his extensive experience in major international fraud and corruption cases. Peter Finbow and Maria Stalbow are names to highlight in the team.
Responsables de la pratique:
Giles Bark-Jones
Autres avocats clés:
Peter Finbow; Sabrik Dhamu; Maria Stalbow; Pat Wilson
Les références
‘Sabrik Dhamu is super-efficient and knows her cases inside-out. Pat Wilson understands and identifies the crucial aspects of a case from the outset.’
‘When I did work for them, all of the team were great to work with: dedicated, hardworking and client focused. Giles Bark-Jones, Peter Finbow and Pat Wilson all stood out as being excellent practitioners who fought their client’s cases to the best of their abilities.’
‘Superb all-round skilful team – able to deal with investigations and pre-charge matters as well as disputes – any client will want them on their side.’
Principaux dossiers
BCL Solicitors LLP
Aptly described as ‘London’s premier tax controversy, tax dispute, and elevated tax risk, legal practice’, BCL Solicitors LLP is a key point of reference for criminal and civil tax matters. Harry Travers leads the team and is extremely experienced in tax avoidance litigation. Ian Burton is the key contact for significant tax investigations, and John Binns excels in tax fraud and evasion matters.
Responsables de la pratique:
Harry Travers
Autres avocats clés:
Ian Burton; Greg Mailer; John Binns; Anoushka Warlow
Les références
‘London’s premier tax controversy, tax dispute, and elevated tax risk, legal practice. ’
‘Harry Travers: incredible attention to detail while focusing on the 360-degree picture. Unparalleled experience, providing the foremost representation. Greg Mailer uniquely innovative, energetically pursuing every avenue on behalf of his clients. A rising star, in the high stakes world of elevated tax risk.’
‘The team at BCL is extremely responsive and gives clear and direct advice in support of its clients. Its knowledge of the tax litigation field is impressive and its commitment to client service excellent’
Principaux dossiers
Charles Russell Speechlys LLP
Distinguished as a ‘strong team combining commercial and private tax expertise’, Charles Russell Speechlys LLP excels in HMRC enquiries and investigations for both private and corporate clients. Equipped with a ‘deep knowledge of tax and of tax investigation’, practice head Hugh Gunson excels in technical tax litigation.
Responsables de la pratique:
Hugh Gunson
Autres avocats clés:
Cora Hardy
Les références
‘Hugh Gunson’s deep knowledge of tax and of tax investigation is incredibly invaluable. If I had a tax dispute with HMRC, this is who I would use.’
‘Hugh Gunson has a deep knowledge of tax and of tax investigation and is great to work with.’
‘They have a strong team combining commercial and private tax expertise and are very capable of managing complex litigation.’
Principaux dossiers
CMS
The tax disputes and investigations team at CMS has a varied practice, with its key work being tax litigation before the tribunals and courts, ADR, HMRC enquiries, tax offences and voluntary tax disclosures. The trio of practice heads is formed of Nicola Hine, who focuses her practice solely on complex tax dispute resolution, and Aaron Fairhurst and Lauren Alder, who both also co-head the wider tax team.
Responsables de la pratique:
Nicola Hine; Aaron Fairhurst; Lauren Alder
Autres avocats clés:
Stephen Hignett; Sam Dames; Phil Anderson
Les références
‘Very sound technically – a number of talented partners.’
‘Nicola Hine and Phil Anderson are both great to work with and very capable.’
‘Broad based experience across a range of tax disputes. For example, the tax team can draw on assistance for judicial review where necessary.’
Principaux dossiers
Corker Binning
Boutique law firm Corker Binning dedicates its practice entirely to business crime and fraud, including criminal tax offences. Jessica Parker sits at the head of the practice and is an expert in proceedings brought by HMRC in relation to allegations of tax fraud. Andrew Smith is an active member of the group and excels in major HMRC investigations.
Responsables de la pratique:
Jessica Parker
Autres avocats clés:
Andrew Smith; Edward Hodgson; Nick Barnard
Les références
‘Brilliant firm. Small but very influential in white collar crime. One of the leading firms in this space in London and has been for years.’
‘This firm is very well managed. They use good and experienced counsel and appear to have recruited well.’
‘Jessica Parker has been involved in several cases with me. She is now the managing partner. Her strategic and tactical views in any given case are on the button. She is charming and, at the same time, tough.’
Principaux dossiers
Kennedys
Kennedys‘ tax disputes and investigations practice is entirely dedicated to tax dispute resolution, from handling complex investigation, disclosures and litigation to transfer pricing and diverted profits matters. Andy Brown heads up the practice and is well known for his work in high-profile tax litigation involving voluntary disclosure. Chris Young and Jennifer Southern are both also names to note.
Responsables de la pratique:
Andy Brown
Autres avocats clés:
Chris Young; Jennifer Southern
Les références
‘Very commercial, understand tax disputes in the context of M&A and on the deal we worked on together they were far more capable at dealing with a global tax remediation than the Big Four accountancy practice on the other side.’
‘Excellent team – great technical knowledge and provide fantastic client and professional support.’
‘Andy Brown is the stand-out member of the team. He rolls up his sleeves and gets stuck in.’
Principaux clients
B&M Retail
Betindex Limited (in liquidation)
Brooklands Project Management Limited
The Hazell Family
Principaux dossiers
- Advising a multinational in real-time advertising technology and programmatic media trading on resolving its global tax risks with an estimated value of $111m.
- Secured the acquittal of two brothers charged with conspiracy to cheat the public revenue and conspiracy to defraud contrary to common law.
- Conducting an internal investigation for the directors of a UK-based IT business into potential bribery, tax irregularities and money laundering.
Kuit Steinart Levy LLP
Equipped with ‘strength and depth of experience and knowledge’, Kuit Steinart Levy LLP is well versed in HMRC investigations, voluntary disclosure, fraud, criminal tax prosecution, offshore tax compliance and tax notices. Robert Levy heads up the practice and is a leading practitioner in contentious tax matters, notably those of suspected serious fraud. Paul Bricknell excels in tax disclosure and investigation work, and Wendi Bussin specialises in regulatory and business crime.
Responsables de la pratique:
Robert Levy
Autres avocats clés:
Paul Bricknell; Wendi Bussin
Les références
‘Kuits have a great mix of technical expertise and client care skills. Applying their knowledge with full regard for the commercial and emotional challenges which this work involves, they give advice and support far beyond a simple book answer.’
‘Wendi Bussin embodies all the qualities which I identify above in the firm. She has consistently provided accurate, relevant and appropriate advice, whilst helping her clients through what can be emotionally charged times. She acts as a professional but also as a human being.’
‘Excellent results, excellent teamwork, and excellent knowledge.’
Principaux dossiers
Mishcon de Reya LLP
The tax disputes and investigation team at Mishcon de Reya LLP brings together expertise in indirect tax, employment-related tax, corporate tax and enforcement by HMRC to provide a thorough offering to its clients. Leading the team is Robert Hartley, who brings strengths in direct tax involved in private client and corporate tax matters, as well as transfer pricing expertise.
Responsables de la pratique:
Robert Hartley
Autres avocats clés:
Cathal McLoughlin; Caitríona Moran
Les références
‘Mishcons are the best of the best. They have an array of talent suited to any client and dispute.’
‘Robert Hartley gets the job done in a calm and respectful manner, he provides good quality instructions, and his easy manner is a winner with clients.
‘Mishcon’s no nonsense, ferocious attitude to litigation is reflected in star performer Cathal Mcloughlin who offers individual and corporate clients with a truly exceptional service.’
Principaux dossiers
Osborne Clarke LLP
Osborne Clarke LLP‘s tax disputes practice is highly regarded for its expertise in the technology sector, as well as in the off-payroll worker sector, including major disputes in labour supply chains and the gig economy. Ian Hyde is the leader of the group and brings specialist knowledge in the tax issues from the digital economy, gig economy and in regulatory compliance. Jack Prytherch and Frances Lewis are both also notable names within the team.
Responsables de la pratique:
Ian Hyde
Autres avocats clés:
Frances Lewis; Jack Prytherch
Les références
‘Pragmatic, clever, and client-orientated. The team are excellent at recognising what the client wants, and finding the most effective way to reach that aim.’
‘Ian Hyde – It’s a real pleasure working with Ian. He is acutely aware of the client needs, and a very skilled lawyer.’
‘Very well-led and efficient team.’
‘Ian Hyde is really bright and experienced. His role as a part-time Tribunal judge is also an added advantage for clients in terms of understanding how judges think.’
‘Great service, very prompt in responses. Thorough.’
‘Depth of understanding clearly demonstrated. Tenacious in getting to the bottom of the subject and all nuances of the topic. Passionate about getting the best client results.’
‘There is a shared responsibility about the team – each member takes the initiative, cares about the case and dedicates their all.’
‘I particularly admire the warmth intelligence, perseverance, humour and ability of Ian Hyde. An absolute maestro – clear and good judgment. Fantastic to work with.’
Principaux clients
Churchill Knight
UK Finance
Veezu
Domino’s Pizza Group PLC
Principaux dossiers
- Advised Churchill Knight & Associates Limited on a tax dispute with HMRC concerning the application of the Managed Service Company tax rules to accountancy service providers.
- Advised representatives of the UK banking and financial services industry on the legality of, and potential methods of challenge against, HMRC financial institution notices.
Penningtons Manches Cooper LLP
Noted by clients for being ‘particularly strong for investigations in sport’, Penningtons Manches Cooper LLP also offers expertise in HMRC investigations, HMRC disclosures, disputed tax liabilities, tax compliance and professional negligence claims in respect of tax matters. The practice is jointly led by the following group of co-heads, Kamran Rehman, Michael Brown, Richard Marshall, James d’Aquino and Alex Fox.
Responsables de la pratique:
Kamran Rehman; Michael Brown; Richard Marshall; James D’Aquino; Alex Fox
Autres avocats clés:
Oliver Cooke
Les références
‘Penningtons Manches Cooper provide a 360 service for their clients which encompasses knowledge and experience across sectors. Problems don’t often fall within a single area of law, and Penningtons has the capability and skill to address issues in a holistic way.
‘Richard Marshall provides a wealth of experience in dealing with high profile and complex matters. Richard is tactically astute and always focused on the potential legal consequences of any legal move. Oliver Cooke is detail focused with a keen eye for the point to turn issues into solutions.’
‘James D’Aquino – a great lawyer with the right instincts.’
Principaux clients
SKAT
Qudos/ Alpha
Principaux dossiers
- Representing an individual who is alleged to be involved in a dividend ‘cum-ex’-type fraud committed against the Danish tax authorities.
- Acting for Boris Frederiksen as Trustee for Alpha Insurance A/S (in bankruptcy) and Qudos Insurance A/S (in bankruptcy) in appeals in the First-Tier Tax Tribunal.
Pinsent Masons LLP
Pinsent Masons LLP has a reputation among its clients for ‘tackling the most complex tax disputes effectively and easily’. The team has ample experience handling large-scale litigation before the higher courts. Jake Landman is an asset to the team and is typically instructed by large corporates in the energy, FS and consume products sectors. Bryn Reynolds serves as the team’s indirect tax expert.
Autres avocats clés:
Jake Landman; Bryn Reynolds
Les références
‘Excellent availability and an understanding of the relative importance of the given matter to the business.’
‘Excellent knowledge and experience in all tax disputes.’
‘Exceptional team capable of tackling the most complex tax disputes effectively and easily. Very collaborative approach internally, with clients and counsel.’
Principaux clients
Skatteforvaltningen (the Danish Customs and Tax Administration)
Centrica Overseas Holdings Limited
Enterprise Zone Litigation – Various clients
Dalriada Trustees Limited
M&S plc
TricorBraun Holdings Inc
Brockwell Capital
Aegon UK
Job&Talent UK Limited
HFD Group Limited
M&J Evans Construction Limited
GRS Roadstone Group Limited
Principaux dossiers
- Acted for Skatteforvaltningen on a claim relating to an alleged fraud against SKAT.
- Acted for Centrica Overseas Holdings Limited, in proceedings before the Supreme Court relating to the deductibility of expenses of management incurred in the preparation of a sub-group for sale to a third party.
- Acting for a collection of syndicates of investors into enterprise zone projects in combined proceedings covering thousands of taxpayers.
Stephenson Harwood
The tax group at Stephenson Harwood is well versed in contentious tax matters, including investigations, enquiries, pre-litigation settlements with HMRC, professional negligence claims and court litigation. The group is noted for its expertise in matters involving private equity and funds, as well as real estate tax. John Meehan leads the team, which is ably supported by Shofiq Miah, who has deep expertise in tax enquiries, investigations and disputes.
Responsables de la pratique:
John Meehan
Autres avocats clés:
Shofiq Miah
Les références
‘Shofiq Miah has been an exceptional support during a high-pressure project. He is always available, is excellent at explaining complex tax issues and above all is commercial and practical where required. He is a true-trusted adviser.’
‘High quality tax team – technically very impressive (great breadth and depth of knowledge). Efficient and organised. And their approach shows that they care a great deal about doing the best possible job for the client.’
‘Shofiq Miah is terrific. He has a deep and wide knowledge of tax law. He cares about doing the best possible job for the client and is very organised and disciplined in his approach to his work.’
Principaux dossiers
- Defended BDO LLP in multi-party High Court proceedings involving a professional negligence claim concerning an allegedly defective tax planning scheme.
- Defended BDO in multi-party High Court proceedings in a professional negligence claim arising from historic issues in relation to tax structuring for a £130m farming estate.
Weil, Gotshal & Manges (London) LLP
Home to a roster of high-profile clients including FTSE 350 companies, Weil, Gotshal & Manges (London) LLP is experienced in a variety of large tax litigation matters. The trio at the head of the practice is formed of Oliver Walker, who specialises in private equity; Jenny Doak, who is an expert in the energy, TMT and infrastructure sectors; and Jamie Maples, who is experienced in litigation, arbitration and investigations. Christopher Marks is also a name to highlight in the team.
Responsables de la pratique:
Oliver Walker; Jenny Doak; Jamie Maples
Autres avocats clés:
Christopher Marks
Les références
‘A great and very experienced team. I like their combination of doing transactional/corporate work en tax litigation.’
‘Oliver Walker stands out for me. He combines his transactional knowledge and litigation capabilities in an excellent way.’