Firms To Watch: Tax litigation and investigations

Kirkland & Ellis International LLP's contentious offering has seen notable growth in 2024, with the additions of James Morgan, from Linklaters, and Ceinwen Rees, formerly of Macfarlanes LLP.

Tax litigation and investigations in London

Herbert Smith Freehills LLP

Herbert Smith Freehills LLP fields ‘an outstanding proactive team’ with a strong reputation acting in tax disputes both domestically and internationally. Areas covered by the department include indirect tax and employment tax disputes, as well as the full scope of direct business tax issues. Nick Clayton, who leads the team, offers expertise in both civil and criminal tax matters, with a record of acting on behalf of UHNWIs, financial institutions, and corporates. Working with Clayton is Michael Hunt, who is dual-qualified as a solicitor and chartered accountant with particular strength in employment tax issues. Dawen Gao is a key name with broad experience across the banking, insurance, and energy sectors, among others.

Responsables de la pratique:

Nick Clayton


Autres avocats clés:

Michael Hunt; Dawen Gao; Avi Haffner


Les références

‘Great depth and breadth.’

‘An outstanding proactive team.’

‘Nick Clayton is a dynamic and intelligent lawyer with exceptional forensic judgment.’

Principaux clients

Bernie Ecclestone


Axiata Group Berhad


Neptune Energy


Moorfield


PacifiCorp Inc.


Orsted


Berkeley Group


Principaux dossiers


  • 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 Orsted in a case heard in the Court of Appeal, on the availability of capital allowances on offshore windfarm development costs.
  • Acting for Moorfield in an appeal to the first-tier tribunal relating to the application of transitional rules for the new carried interest tax regime that was introduced in 2015.

Joseph Hage Aaronson LLP

Joseph Hage Aaronson LLP, a respected tax boutique, offers ‘incomparable experience of litigating major tax cases’, with a strong track record appearing before the First-Tier Tribunal, Upper Tribunal, High Court, Court of Appeal, and the UK Supreme Court, as well as the CJEU. In addition to its aptitude for litigation, the firm handles arbitration and investigations, representing a diverse range of domestic and international clients in the full spectrum of contentious tax. Graham Aaronson KC, who ‘needs little introduction’, co-leads alongside fellow founding partner Michael Anderson, whose practice covers both civil and criminal tax disputes. Simon Whitehead specialises in direct tax, while Iain MacWhannell is noted for his strength in VAT, in addition to a strong fraud/avoidance/abuse tax practice. Also key are Daniel Margolin KC, who has experience appearing before the Supreme Court, and Helen McGhee, noted for her aptitude in international tax disputes.

Responsables de la pratique:

Graham Aaronson KC; Michael Anderson


Autres avocats clés:

Iain MacWhannell; Simon Whitehead; Paul Farmer; Daniel Margolin KC; Helen McGhee


Les références

‘Helen McGhee has excellent knowledge of private client tax and great expertise in handling disputes and litigation at all levels of the court system.’

‘THE top tier tax litigation firm in the UK. Incomparable experience of litigating major tax cases. Partners have unrivalled experience, knowledge and tactical nous.’

‘Iain MacWhannell is excellent. He is commercial and astute, but also personable. He is the go-to lawyer for major VAT cases.’

Principaux clients

British American Tobacco PLC


Prudential PLC


AXA PLC


Fidelity International


Ford Motor Company


GKN Aerospace Limited


‘The VAT Umbrella Appeals’


ABRDN PLC


Shield Contract Services (UK) Limited


Dandara Group


Sports Invest Ltd


Principaux dossiers


  • Acting as Lead Solicitors in the Franked Investment Income GLO, advising 17 multinationals in their challenge to the UK’s dividend taxation scheme.
  • 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 multinational businesses seeking repayment of unlawfully levied tax on foreign portfolio dividend income following the successful decision in the Supreme Court in the Prudential case.

Slaughter and May

Slaughter and May fields ‘one of the best tax teams in the country’, at the forefront of key issues such as partnership tax. The substantial team is equipped to offer full support in matters such as transfer pricing and tax residence issues, with a robust criminal tax offering. Jointly leading the team are Richard Jeens, a notable thought leader with experience in complex multijurisdictional mandates, and Dominic Robertson , whose expertise extends to transfer pricing and DPT issues. ‘Grandee partner’ Ewan Brown specialises in providing advice to financial institutions facing litigation and investigations, while Mike Lane contributes further expertise in VAT. Sarah Osprey, who made partner in May 2023, has experience advising prominent international clients on a range of matters, including state aid.

Responsables de la pratique:

Richard Jeens; Dominic Robertson


Autres avocats clés:

Ewan Brown; Mike Lane; Sarah Osprey


Les références

‘Big guns – for the right client, they offer everything. ’

‘Dominic Robertson – a brilliant tax lawyer with loads of litigation experience. Dominic never fails to put the client first.

‘Ewan Brown – grandee partner on the contentious side brings decades of experience to tax disputes and has good strategic insights.’

Principaux clients

BlueCrest


GE Financial Investments


Takeda


Principaux dossiers


A&O Shearman

A&O Shearman‘s robust contentious tax offering aids in litigation, arbitration, and investigations, both within the UK and internationally. Charles Yorke has experience handling high stakes disputes in the financial, energy, and infrastructure sectors, and jointly leads the department alongside Chris Harrison, who serves as the firm’s global head of tax. Eve Giles is an expert in financial crime matters relating to tax, while senior partner Lydia Challen is a key contact for contentious matters relating to structuring issues.

Responsables de la pratique:

Charles Yorke; Chris Harrison


Autres avocats clés:

Eve Giles; Lydia Challen


Les références

‘Technically very able and good with clients.’

‘Charles Yorke provides good, sensible advice in very complex transactions.’

‘Great depth.’

Principaux clients

Investec Bank plc


Lloyds Banking Group


Principaux dossiers


  • Advising a consumer business on a dispute with HMRC regarding claims by its UK operations for tax deductions on the interest arising out of intra-group debt.
  • Advising a major UK retailer in relation to an HMRC enquiry into a subsidiary, and potential claims against the subsidiary’s former owner.
  • Advising a high-profile client in relation to an investigation by HMRC into its internal group structure.

Ashurst

Ashurst fields a 'very knowledgeable' team adept in direct and indirect tax disputes, active for a diverse client roster which includes financial institutions, major funds, and premium corporates. The department is equipped to handle complex international disputes, including transfer pricing and state aid issues. Nicholas Gardner leads the team, and has experience handling tax disputes before all levels of the UK courts. Paul Miller specialises in the financial services industry, and has experience in disputes relating to unallowable purpose. Sara Mardell has strength in indirect tax, and a growing practice advising on judicial review claims.

Responsables de la pratique:

Nicholas Gardner


Autres avocats clés:

Sara Mardell; Paul Miller


Les références

‘Ashurst have a really great tax team – they are all very knowledgeable with enormous amounts of experience and great client service.’

‘Sara Mardell is extremely bright and a joy to work with. Nicolas Gardner has a wealth of experience.’

‘Very knowledgeable regarding tax litigation and legislation. Good client service – fast response and clear communication.’

Principaux clients

Imperial Brands PLC


Odfjell Drilling (UK) Limited (ODUK)


Hastings Insurance Services Limited


Roadchef


Principaux dossiers


  • Acting for Imperial Brands PLC on its appeal to the CJEU for the annulment of the EC Decision that the UK CFC rules were unlawful state aid
  • Acting for Odfjell Drilling on its appeal to the First-Tier Tribunal against an assessment to employer’s NICs in relation to workers on oil rigs
  • Acting for Roadchef in relation to the resolution of a PAYE and NICs assessments by way of tripartite mediation proceedings and subsequent settlement agreement

Baker McKenzie

Baker McKenzie‘s department houses lawyers, economists and accountants, delivering ‘strong technical expertise and awareness of commercial reality’. The group offers comprehensive support in contentious tax, covering indirect tax disputes, transfer pricing, state aid investigations, and corporation tax disputes. David Jamieson co-leads the team alongside Jessica Eden, with Jamieson focusing on contentious VAT matters, while Eden spearheads the corporate tax disputes offering. Patrick O’Gara is particularly adept in issues relating to DPT, with strength in the technology, pharmaceutical, and professional services sectors. Jukka Karjalainen leads on transfer pricing, with varied prior experience, which includes working in-house at a multinational mining corporation.

Responsables de la pratique:

David Jamieson; Jessica Eden


 


Autres avocats clés:

Patrick O’Gara; Jukka Karjalainen


Les références

‘The leading tax team in London at the moment.’

‘Jessica Eden is pre-eminent and gives good, technically able, advice.’

‘Baker McKenzie have deep expertise across international indirect tax matters, enabling them to advise on highly complex issues from legislative positions through to authority engagement and litigation strategy.’

Principaux clients

Core Media


Electronic Arts


European Tyre Enterprise Limited


Hutchison 3G Limited


Marriott


MDU (Medical Defence Union Limited)


Thames Television


The Prudential Assurance Company Limited


Takeda


UK Power Networks


Principaux dossiers


  • Advised the Kwik-Fit Group on a long running dispute with HMRC concerning whether a restructuring of the group’s inter-company balances gives rise to an unallowable purpose for the existing receivables.
  • Represented Prudential in the Upper Tribunal in November 2022. The case concerned 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

The ‘good all round team with lots of practical experience’ at Bryan Cave Leighton Paisner maintains strong coverage of civil and criminal tax matters, with a strong track record in high profile test cases of national significance. Elizabeth Bradley, who is the firm’s global head of tax, leads the department alongside Kate Ison, praised for her ability to ‘explain issues succinctly and effectively‘. Ison covers both direct tax and VAT, with experience handling HMRC enquiries and investigations. Alan Sinyor  is the resident indirect taxation expert, covering all contentious and non-contentious issues relating to VAT and Customs Duties. Kyle O’Sullivan joined the group from Slaughter and May in April 2024.

Responsables de la pratique:

Elizabeth Bradley; Kate Ison


Autres avocats clés:

Alan Sinyor; Kyle O’Sullivan


Les références

‘A good all round team with lots of practical experience.’

‘Elizabeth Bradley and Kate Ison are good lawyers with great technical skills.’

‘A friendly team that work well together.’

Principaux dossiers


DLA Piper

DLA Piper‘s ‘highly knowledgeable, experienced, skilful, responsive‘ team works within the firm’s global framework to aid clients facing audits and tax disputes worldwide. The group demonstrates particular aptitude in transfer pricing, aiding multijurisdictional clients with intensive, global investigations. Jason Collins leads the team, and has expertise in all stages of audits, enquiries, and appeals, with areas of particular strength including employment tax, DPT, and transfer pricing. Stuart Walsh specialises in indirect tax, advising numerous prominent multinationals in contentious matters in this area. Randall Fox leads the team’s transfer pricing team. Also key are Clara Boyd, a VAT specialist with experience conducting internal investigations, and Lauren Redhead, who is experienced acting for multinationals.

Responsables de la pratique:

Jason Collins


Autres avocats clés:

Randall Fox; Lauren Redhead; Richard Woolich; Clara Boyd; Stuart Walsh


Les références

‘Very knowledgeable and communicate well.’

‘Knowledge, cost management, communication skills.’

‘Rapidly developing profile in the market.’

Principaux clients

JTI Acquisitions Company (2011) Limited


Komatsu America Corp


NatWest Markets plc


Mid Ulster District Council


CCLA Investment Management Limited


Principaux dossiers


  • Acting for JTI Acquisitions Company (2011) Limited in an appeal concerning the proper interpretation and application of the unallowable purpose rule for loan relationships.
  • Acting for Natwest Markets plc in a high value, high profile multi-party dispute arising from missing traders in its carbon credit supply chains defaulting on VAT due to HMRC.
  • Acting for Mid Ulster District Council in challenging HMRC’s denial of reclaims of VAT wrongly accounted for on sports and leisure services.

Ernst & Young LLP

Ernst & Young LLP's growing team is experienced at all levels of the UK tax courts, with aptitude in judicial review cases. The group benefits from the substantial support of the larger firm, equipping the group with strength in VAT, landfill tax, income and corporation tax, and EU disputes. Boaz Goren heads the team alongside Mitchell Moss and Julian Balson. Goren has significant experience in both litigation and ADR. Moss leads on indirect tax disputes, while Balson is noted for his strength advising on enquiries and investigations. Elyse Waller and Dan White are key names in the team.

Responsables de la pratique:

Boaz Goren; Mitchell Moss; Julian Balson


Autres avocats clés:

Elyse Waller; Dan White


Principaux clients

Biffa plc


Muller UK & Ireland Group LLP and other companies


A multinational asset manager


Dolphin Drilling Limited


Thyssenkrup Materials (UK) Ltd


Principaux dossiers


  • Advising Biffa plc on a wide ranging and complex Landfill Tax enquiry.
  • Representing Dolphin Drilling Limited at First-tier Tribunal through to the Court of Appeal on whether a tender support vessel providing tender assisted drilling services is a ‘relevant asset’.
  • Representing Muller UK & Ireland Group LLP in its appeal following HMRC’s decision to disallow an amortisation of acquisition costs following a business restructure.

Fieldfisher

Fieldfisher boasts 'total domain expertise', with coverage of enquiries, litigation, arbitration, appeals, and judicial review, in addition to professional negligence and lobbying services in the tax sphere. Team lead George Gillham is highly experienced in both civil and criminal tax disputes, and has prior experience working within HMRC as a tax inspector. Philippe Freund is particularly adept in international and cross-border matters. Matthew Sharp covers matters relating to employment tax, with a robust professional negligence practice. Siobhan Gillespie is active for both individuals and corporates in a range of matters. Barrister Christopher Kientzler has experience in litigation relating to the taxation of umbrella companies.

Responsables de la pratique:

George Gillham


Autres avocats clés:

Philippe Freund; Matthew Sharp; Siobhan Gillespie; Christopher Kientzler


Les références

‘Total domain expertise, dedication to client cause professional stamina.’

‘This is a stand-out team for complex questions of tax litigation, and in particular matters of professional negligence. Their combination of first-rate tax knowledge and litigation experience is second to none. ’

‘Matthew Sharp is a particular stand out individual. I have no hesitation in sending clients to him and I know that he will treat them well, as he combines client understanding with technical excellence.’

Principaux clients

Alternative Resolution Consultancy LLP


Eclipse Film Partners LLPs


L Rowland & Co (Retail) Limited (Phoenix Medical)


Exchequer Solutions Limited


Sunrise Medical Ltd, TGA Mobility Limited


Drive Devilbiss Healthcare Limited


Electric Mobility Euro Limited


Freerider Luggie Limited


Sunrise Medical B.V. & Sunrise Medical Logistics B.V.


Thomas Hoegh


Morten Hoegh


Hoegh Capital Partners


Aramark Limited


The CBD Flower Shop Limited


Principaux dossiers


  • Advising 376 individuals on settlement with HMRC in relation to the Eclipse Film partnerships
  • Advising Thomas and Morten Hoegh and Hoegh Capital Partners in relation to a professional negligence claim against their previous advisers
  • Advising Sunrise Medical Ltd, Electric Mobility Euro Ltd, TGA Mobility Ltd, Drive DeVilbiss Ltd, and Freerider Luggie Limited on a customs duty dispute with HMRC.

KPMG Law

KPMG acts for a prestigious spread of clients, including numerous prominent multinational groups. The group is highly active on behalf of major financial institutions, with further strength across the industrial, gaming, and energy sectors. Jointly leading the department are Angela Savin, a specialist in direct taxes active for both corporates and high-net-worth individuals, and Matthew Fleming, who leads on indirect tax, including VAT, customs duty, and excise. Colette Van Zyl shares indirect tax as an area of specialism, with particular emphasis on VAT matters. Barrister and accredited mediator Lee Ellis is highly experienced in both domestic and international disputes.

Responsables de la pratique:

Angela Savin; Matthew Fleming


Autres avocats clés:

Colette van Zyl; Lee Ellis


Principaux clients

Altrad Services Limited


Credit Suisse


DHL Air Ltd


Delinian Limited


GAP Group Limited


Genesis Cancer Care Limited


Glint Pay Services Limited


Gloucestershire Hospitals NHS Foundation Trust


HSBC Bank plc


Knot Builders Ltd


Kopparberg/Cider of Sweden


PD Ports Services Limited


Robert Wiseman and Sons Limited


Simple Energy Ltd


Sims Group UK Ltd


Sonder Europe Limited


United Grand Lodge of England


Principaux dossiers


  • Acting for HSBC in a dispute with HMRC about whether UK branches of non-UK incorporated global service centre entities that provide services to the banking group are entitled to be members of the bank’s UK VAT group.
  • Assisted GAP Group Limited in a dispute with HMRC over whether one instance of plant hire and supply of fuel constitute separate supplies of plant hire and fuel.
  • Representing DHL in a precedent-setting win over HMRC before the First-tier Tribunal in a dispute about End Use authorisations.

Macfarlanes LLP

Macfarlanes LLP is ‘a high quality tax litigation outfit with excellence at every level’, adept in direct and indirect tax disputes, in addition to risk management advice. Gideon Sanitt heads the team, and is described as ‘excellent, very clever, and commercial’. Sanitt is active for both individuals and corporate clients, and has significant experience in litigation and investigations. Sophie Rhind has strength in partnership taxation, and provides key expertise in ADR.

Responsables de la pratique:

Gideon Sanitt


Autres avocats clés:

Sebastian Prichard Jones; Sophie Rhind; Jackelyn West


Les références

‘A high quality tax litigation outfit with excellence at every level.’

‘Gideon Sanitt – huge experience, runs a good team.’

‘Deep knowledge, very collaborative. ’

Principaux clients

Royal Mail Group Limited


CDC Administration LLP


HFFX LLP


Odey Asset Management LLP


Principaux dossiers


  • Advising Odey Asset Management  on a dispute with HMRC regarding the tax impact of a historic incentivisation and retention mechanism for key partners.
  • 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.

PwC LLP

PwC LLP‘s client base includes FTSE 100 groups, Premier League football clubs, and high-net-worth individuals, with the team experienced in the full range of sensitive and complex tax disputes. Mark Whitehouse heads the direct tax practice, co-leading the department alongside David Anderson, who leads on indirect tax. Whitehouse counts transfer pricing and group litigation actions among his key strengths, while Anderson is noted for his aptitude in VAT. Peter Johnson is experienced in multidisciplinary tax disputes, and has a strong track record in litigation.

Responsables de la pratique:

Mark Whitehouse; David Anderson


Autres avocats clés:

Peter Johnson; Victor Cramer


Les références

‘The PWC disputes litigation team is probably the strongest tax team in the UK for mainstream tax litigation. It routinely appears in all the significant cases in indirect tax, especially VAT. Their all-round ability to resource a case is also phenomenal.’

‘Great depth and breadth’

‘The recruitment of Victor Cramer from Stewarts has strengthened the team – he is very much ‘on the ball’, considered & easy to work with.’

Principaux clients

Target Group Limited


Boehringer Ingelheim Limited


Thomas Holdings Limited and Thomas Estates Limited


Parker Hannifin (GB) Limited


Reckitt Benckiser Group Plc


Hippodrome Casino Limited


St Patrick’s International College Limited


Experian Plc


Genus plc


Informa plc


Just Eat plc


Keller Group plc


Merlin Entertainments Limited


Royal Mail Group plc


Smith & Nephew plc


Ultra Electronics Holdings plc


Principaux dossiers


  • Represented Target in its ground-breaking appeal concerning the proper scope of certain financial services exemptions from VAT.
  • Representing a number of pharmaceutical companies in litigation over HMRC’s rejection of their claims for repayment of output tax.

Quinn Emanuel Urquhart & Sullivan, LLP

Quinn Emanuel Urquhart & Sullivan, LLP is a leading name in private client tax disputes, with a prestige client base of ultra-high-net-worth individuals, including those facing complex multijurisdictional proceedings. The group additionally acts for corporate groups facing a range of direct and indirect tax disputes. Liesl Fichardt leads the team, and is highly experienced in complex tax disputes, with expertise in both litigation and arbitration. Epaminontas Triantafilou is noted for his record in international arbitration, as is Justin Michaelson, whose practice additionally covers white collar crime. Emily Au covers litigation and investigations, and conducts advocacy before the UK tax tribunals.

Responsables de la pratique:

Liesl Fichardt


Autres avocats clés:

Epaminontas Triantafilou; Justin Michaelson; Emily Au


Principaux clients

Unite Group


Kellas Midstream Limited


Jane Street Group, LLC


Bauer Media


Barrick Gold Corporation Group and international subsidiaries


Principaux dossiers


  • Acting for Unite Group plc in the lead tax disputes and appeals regarding VAT applicable to replacement cladding and fire safety works.

RPC

RPC covers tax investigations, litigation, and judicial review cases, with a strong ADR offering. The group benefits from including multiple former HMRC members, lending expertise in the full range of civil and criminal tax procedures. Adam Craggs leads, and has longstanding experience in direct and indirect tax disputes. Craggs is highly active as a thought leader, lecturing and writing extensively on tax matters. Michelle Sloane has key strength in criminal tax matters, and is active on behalf of both individuals and corporates. Harry Smith brings experience working within HMRC, and has broad sector expertise.

Responsables de la pratique:

Adam Craggs


Autres avocats clés:

Michelle Sloane; Harry Smith


Les références

‘Great team, very experienced and competent. Always reassuring to have their expertise onboard.’

‘Genuine specialists, proactive, and consistently keep you updated on progress.’

‘RPC take charge of difficult issues to allow the group to continue to focus on its day-to-day activities. They are fully committed to their clients’ needs and fully understand their clients’ businesses.’

Principaux clients

Frasers Group PLC


Universal Cycles


Newcastle United Football Club


Steven Hoey


Clipperton & Lloyd


Principaux dossiers


  • Acting for Newcastle United FC in relation to a multi-faceted dispute with HMRC stemming from an enquiry into agents’ fees that started with a dawn raid.
  • Acting for Universal Cycles Limited on a long-running customs matter concerning the application of Anti-Dumping Duty, Customs Duty and VAT on the importation of bicycles from South-East Asia.
  • Acting for Stephen Hoey on an appeal to the Supreme Court concerning the tax treatment of employee benefit trusts and the operation of the PAYE system.

Simmons & Simmons

Simmons & Simmons has core strength advising clients in the financial services, asset management, and environmental sectors, and benefit from the firm's broader full service offering. Heather Rowlands leads the team, and is praised by clients for her 'encyclopaedic knowledge of the trickiest elements of tax law'. Rowlands is dual qualified as a solicitor and Chartered Tax Adviser, and has a practice which includes offshore litigation and indirect tax. 'Star in the making' Craig Kirkham-Wilson covers both civil and criminal tax disputes, and is qualified as a solicitor advocate.

Responsables de la pratique:

Heather Rowlands


Autres avocats clés:

Monique Van Herksen; Craig Kirkham-Wilson


Les références

‘This is one of the most exceptional teams you will come across, in terms of work ethic, intellectual firepower, and efficiency.’

‘Heather Rowlands has an endless capacity for hard work, and nobody is more on top of the details of a complex case than her. Craig Kirkham-Wilson is a star in the making – A1 intellectually, and a master tactician in complex cases.’

‘An extremely well-resourced, hard-working and diligent team.’

Principaux clients

Willis Towers Watson


Christopher Rokos (principal of Rokos Capital Management)


Augean Limited


Davidson Kempner Capital Management


The Saint-Gobain group


UBS


RNIB


Principaux dossiers


  • Acted for Christopher Rokos, a prominent hedge-fund manager, in a professional negligence claim against a Big 4 accountancy firm and a US law firm.
  • Acting for Augean, a leading environmental services business, in ‘test case’ appeals relating to the landfill tax liability of waste from numerous industrial processes.
  • Acting for Burlington Loan Management DAC in a multi-million pound tax treaty dispute arising out of the $7billion Lehman Brothers International (Europe) administration surplus.

Eversheds Sutherland (International) LLP

Eversheds Sutherland (International) LLP is particularly adept in indirect tax disputes, representing prominent clients in the full range of VAT and customs matters. The group has additional strength in international tax, benefiting from the firm’s global network in its handling of multijurisdictional and cross-border matters. Ben Jones leads, and maintains both a contentious and non-contentious practice. Edward Griffiths is a key name, with experience in judicial review claims.

Responsables de la pratique:

Ben Jones


Autres avocats clés:

Edward Griffiths; Robert Waterson


Les références

‘Really responsive, commercial.’

‘Really easy to deal with, explained difficult concepts to us in easy to understand language. Stand out individuals Edward Griffiths.’

‘Good coverage across different taxes, able to advise on all relevant areas.’

Principaux clients

PriceWaterhouseCoopers LLP


Aozora GMAC Investment Ltd


Principaux dossiers


Hogan Lovells International LLP

Hogan Lovells International LLP fields a team with broad disputes expertise, including litigation and investigations. The group has strength in corporation tax, employment tax, and VAT, with aptitude in the education, financial services, and technology sectors. Rupert Shiers, who is the firm's head of the European tax disputes team, leads the department.

Responsables de la pratique:

Rupert Shiers


Principaux clients

Bank of New York Mellon


eBay


Eurasian Resources Group


General Reinsurance


Groupon


Reach plc


TripAdvisor


Principaux dossiers


  • Advised Reach Plc on a high sensitivity, high value enquiry into deductibility of “phone hacking” expenses.
  • Advised Eurasian Resources Group (ERG) / Eurasian Natural Resources Corporation Limited (ENRC) on a high value VAT input tax enquiry with HMRC using novel “establishment” arguments.
  • Advised General Reinsurance on a Unique HMRC negotiation on interaction of FSMA 2000 court order and corporation tax compliance rules.

Kingsley Napley LLP

Kingsley Napley LLP‘s contentious tax team offers support in both civil and criminal tax matters, and is composed of ‘experienced, skilful practitioners’. Leading the team is Waqar Shah, ‘undoubtedly one of the most dynamic tax litigation partners in the industry’, who has experience representing individuals and corporate clients in both litigation and ADR. Criminal tax specialist David Sleight‘s practice includes matters relating to fraud, tax evasion, and overseas corruption. Krishna Mahajan joined the team from Stewarts in January 2024.

Responsables de la pratique:

Waqar Shah


Autres avocats clés:

David Sleight; Alun Milford; Louise Hodges; Krishna Mahajan


Les références

‘My biggest impression is that the team is very “Kingsley Napley”, in terms that it provides bespoke and tailored professional services that meet each individual client’s needs.’

‘Waqar has extensive knowledge and experience in dealing with matters related to tax investigation and litigation.’

‘David Sleight is hard-working, smart, emotionally intelligent and covers all the bases. An excellent advisor to have in your corner.’

Principaux dossiers


Norton Rose Fulbright

Norton Rose Fulbright has strength in international tax disputes, covering a diverse range of issues including tax residence, main purpose tests, and disputes relating to the correct interpretation of double tax treaties. Global head of tax Dominic Stuttaford, who ‘has a brain the size of a planet’, co-leads the department alongside Matthew Hodkin, noted for his strength in the energy, infrastructure, and transport sectors. Ruth Cowley is a key name.

Responsables de la pratique:

Dominic Stuttaford; Matthew Hodkin


Autres avocats clés:

Michael Alliston; Ruth Cowley


Les références

‘The research and development tax team have a great amount of in-depth knowledge in this area.’

‘Michael Alliston is a first-rate partner. Extremely technically able and bright, with real attention to minute details.’

‘Dominic Stuttaford has a brain the size of a planet, and what he doesn’t know about tax law isn’t worth knowing. It’s impossible not to feel in awe when he explains a complex tax statute or authority with such ease and simplicity. He’s a stunningly impressive tax practitioner.’

Principaux clients

HSBC


Takeda (formerly Shire)


Royal Bank of Canada


Principaux dossiers


  • Acting for HSBC in a restitution claim in the Franked Investment Income Group Litigation Order.
  • Acting for Takeda (formerly Shire) in a restitution claim in the Stamp Taxes Group Litigation Order relating to Stamp Duty Reserve Tax.
  • Acting for client in its successful appeal to the Court of Appeal in relation to a dispute with HMRC concerning the taxation of payments relating to North Sea Oil production.

Pinsent Masons LLP

Pinsent Masons LLP covers all aspects of direct and indirect taxation, with a strong record in high profile and large scale litigation, including multiple cases before the Supreme Court. Team lead Steven Porter acts for both private individuals and corporate clients facing high-stakes tax disputes, and has a ‘fantastic legal mind and grasp of subject matter’. Key names within the team include Jake Landman, who has particular strength in the financial services sector, and Bryn Reynolds, an expert in indirect tax disputes who joined the group from Simmons & Simmons in November 2023.

Responsables de la pratique:

Steven Porter


Autres avocats clés:

Jake Landman; Ian Robotham; Sam Wardleworth; Bryn Reynolds


Les références

‘A good range of experience and sound technical skills.’

‘Jake Landman stands out for great client care and sensible litigation advice.’

‘Positive and friendly manner, and puts the client first.’

Principaux clients

Skatteforvaltningen


The Gala Film Partners LLP


Centrica Overseas Holdings Limited


City Football Group / MCFC


Various enterprise zone syndicates


Principaux dossiers


  • Acted for the Danish Tax Authority on a large-scale alleged fraud against them, including on the proper extent of the longstanding Revenue Rule.
  • Acting for Centrica on a corporation tax deduction case claimed by an intermediate holding company. This was heard by the Supreme Court in early 2024.
  • Advising Gala Film Partners LLP in its appeal to the FTT against a closure notice which removed £98 million of losses against which relief was claimed by its members against income tax liabilities.

Skadden, Arps, Slate, Meagher & Flom (UK) LLP

Skadden, Arps, Slate, Meagher & Flom (UK) LLP specialises in high value tax disputes of a highly complex, international nature. Transfer pricing and matters relating to state aid are within the team’s scope, which provides full support in litigation and ADR procedures. James Anderson, who leads the firm’s European tax practice, jointly heads the department alongside Kate Davies KC, noted for her skill in arbitration. Alex Jupp is experienced advising clients facing audits.

Responsables de la pratique:

James Anderson; Kate Davies KC


Autres avocats clés:

Alex Jupp


Les références

‘The team is tuned into client needs, focused, and very efficient.’

‘Small, efficient team of experts. Think outside the box when appropriate, not afraid to speak up, bringing a lot of value to the table.’

Principaux clients

Victaulic Europe


Vodafone


Principaux dossiers


  • Advising Victaulic Europe before the EU General Court on its application for the annulment of the EC 2016 Belgium “Excess Profit Rulings” state aid decision.
  • Advising a quantitative trading firm in connection with interest rate and withholding tax appeals against HMRC determinations, and appeal to the IRU as well as consideration of US-UK treaty MAP opportunities.
  • Advising a leading technology company in connection with audit and strategic advice relating to HMRC enquiries into on-shoring of intangibles worth approximately $9 billion.

Stewarts Law LLP

Stewarts Law LLP represents individuals and corporate clients in the full range of tax disputes, including professional negligence claims. The group is praised for its ‘second to none technical expertise’, which it utilises across the financial services, transport, and consumer goods sectors, among others. David Pickstone leads the team, and has significant experience in both litigation and out-of-court negotiations. Additions to the team over the course of 2023 include Giles Salmond, an expert in indirect tax who joined from Eversheds Sutherland (International) LLP, and Matthew Greene, formerly of Osborne Clarke LLP.

Responsables de la pratique:

David Pickstone


Autres avocats clés:

Matthew Greene; Anastasia Nourescu; Giles Salmond


Les références

‘They have specialist tax professionals who in some cases have worked for HMRC and understand the inner workings of that public body.’

‘Very focussed on the issues, attentive and concise with explanations and a business like attitude to addressing the task at hand.’

‘David Pickstone and Anastasia Nourescu have been excellent with the way they have broken down complex issues and communicated them to me, the client. The issues have been dealt with in a prompt business like manner.’

Principaux clients

Singleton Birch Limited and FCC Recycling UK Limited


Tayto Group Limited


The Noble Organisation


Principaux dossiers


  • Acted for a company director in a successful tribunal appeal against a £5m penalty.
  • 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.
  • Acting in a tax dispute for Tayto Group.

Weil, Gotshal & Manges (London) LLP

Weil, Gotshal & Manges (London) LLP acts for a prestige client base of high profile clients, with experience advising on complex multijurisdictional disputes. The department is jointly led by Oliver Walker, Jenny Doak, and Jamie Maples. Walker has expertise in private equity, Doak covers judicial review cases and contractual disputes in addition to litigation, and Maples brings experience in arbitration and investigations. Solicitor advocate Christopher Marks is a key name.

Responsables de la pratique:

Oliver Walker; Jenny Doak; Jamie Maples


Autres avocats clés:

Christopher Marks


Les références

‘The WGM team is exceptional in terms of quality and effectiveness. They were always on top of every point in the litigation and handled the clients with total aplomb.’

‘Jenny Doak is a stand-out. Very experienced in oil and gas.’

‘The team has a very practical and problem-solving approach, which is very valuable.’

Principaux dossiers


Bark&co

Bark&co fields a 'very well regarded and experienced team' with a growing reputation in civil litigation and investigations, in particular VAT and excise duty cases. The group additionally boasts core strength in criminal tax matters, including high profile tax fraud. Giles Bark-Jones leads the team, with a strong reputation in international tax fraud and corruption. White collar crime expert Peter Finbow and fraud specialist Maria Stalbow are core team members.

Responsables de la pratique:

Giles Bark-Jones


Autres avocats clés:

Peter Finbow; Sabrik Dhamu; Maria Stalbow


Les références

‘A very well regarded and experienced team. Well suited to deal with both criminal and civil fraud cases.’

‘Giles Bark-Jones is very experienced and knows how to ensure his client’s interests are best looked after. He is commercially astute and tactically aware.’

‘They have a growing tax and investigations profile arising out of their massive presence in criminal defence.’

Principaux dossiers


  • Acting for an individual in relation to an HMRC investigation concerning online gambling activity in Turkey.
  • Acting for one of multiple individuals charged concerning an alleged criminal scheme by which a number of directors of a film production company cheated the Revenue out of £13m+ of VAT.
  • Acted for a defendant charged following an HMRC investigation into relation to an alleged £3.5m Cheat on the Revenue and associated money laundering offences.

BCL Solicitors LLP

BCL Solicitors LLP is particularly active on behalf of high-net-worth individuals, and provides support in both civil and criminal tax matters. Harry Travers, who leads the team, has expertise in tax investigations and white collar crime. Ian Burton and John Binns cover tax fraud, including on behalf of both individuals and prominent organisations. Greg Mailer made partner in September 2023.

Responsables de la pratique:

Harry Travers


Autres avocats clés:

Ian Burton; Greg Mailer; John Binns; Anoushka Warlow


Les références

‘The team has outstanding experience in tax investigations and interacting with HMRC. They give advice to corporates and individuals who benefit from their wide-ranging expertise and experience in this highly complicated and technical area.’

‘Harry Travers – simply the man to go to with a complex or sensitive tax problem. He has such enormous experience and feel for the intricacies of tax investigations, and understands how best to predict difficult situations and get the most impressive outcomes for clients.’

‘Greg Mailer – very well liked by clients, and has very high profile civil and criminal investigations under his wing at the moment. He rightly delivers his legal and strategic opinion with confidence and is easily understood in this complex area.’

Principaux dossiers


Charles Russell Speechlys LLP

Charles Russell Speechlys LLP advises on HMRC enquiries and investigations, as well as tax litigation, acting on behalf of both private clients and corporates. The group additionally offers support in tax-related professional negligence matters. Team lead Hugh Gunson is 'technically brilliant but with a keen eye on strategy', and covers a broad range of disputes.

Responsables de la pratique:

Hugh Gunson


Les références

‘In a very specialist area, this is a team that really knows what it is doing. Top class.’

‘Hugh Gunson, technically brilliant but with a keen eye on strategy. ’

‘Strong private client technical tax skills.’

Principaux dossiers


CMS

CMS‘ disputes team works with the support of the firm’s substantial tax offering, catering to a prestige client base of multinationals, facing a range of complex disputes. The group takes an active role in thought leadership in the area. Stephen Hignett, who co-heads the broader tax team, leads the department. Sam Dames has particular strength in the financial services, infrastructure, and life sciences sectors.

Responsables de la pratique:

Stephen Hignett


Autres avocats clés:

Sam Dames


Les références

‘A united team that manages cases efficiently and effectively on an independent basis.’

‘Great attention to detail.’

‘The tax litigation department at CMS is fully resourced and has multidisciplinary capacity and so is able to combine the in depth knowledge of tax law needed to conduct a tax dispute with the practical knowledge of procedure which is nowadays an essential part of fiscal dispute resolution.’

Principaux clients

SSE Generation Limited


UK Finance


Archax


Principaux dossiers


  • Acted for SSE Generation Limited in its case before the Supreme Court concerning capital allowances claim on £200m of expenditure incurred when constructing the Glendoe hydroelectric power station.
  • Advised representatives of the UK banking and financial services industry on the legality of, and potential methods of challenge against, HMRC financial institution notices.
  • Advised Archax to successfully bring about a change to the “growth market” exemption under stamp tax legislation, as announced at the Autumn Statement 2023.

Corker Binning

Corker Binning, the 'pre-eminent boutique firm for criminal law issues', acts for individuals facing highly complex tax disputes, including major criminal investigations. The group is experienced handling international matters, coordinating across multiple jurisdictions. Jessica Parker leads the team, and has experience acting in civil and criminal tax matters. Andrew Smith is a key name, with a strong track record in international matters.

Responsables de la pratique:

Jessica Parker


Autres avocats clés:

Andrew Smith; Nick Barnard


Les références

‘First-rate boutique white collar crime firm. One of the best in the country.’

‘Peter Binning and David Corker set the bar high for the new crop of bright young partners. Both are in the top rank of white collar defenders, with decades each of experience in all the big cases’.’

‘Nick Barnard – a new partner with a big future – brings a powerful perspective to the most complex investigations and enlivens the densest of material with a memorable wit.’

Principaux dossiers


  • Secured the largest ever joint criminal-civil settlement for an individual defendant for Bernie Ecclestone in his HMRC/CPS tax fraud prosecution.

Kennedys

Kennedys fields a rapidly growing team, with established expertise in indirect tax disputes, in addition to a range of criminal tax matters. ‘Tactically astute’ Andy Brown leads the team, with experience in litigation and ADR. Brown joined the team in 2023 from Bird & Bird, alongside Chris Young, an expert in investigations, and Jennifer Southern.

Responsables de la pratique:

Andy Brown


Autres avocats clés:

Chris Young; Jennifer Southern


Les références

‘The team have significant experience in tax disputes, fearlessly representing clients’ best interests. They combine astute strategic thinking with comprehensive and meticulous analysis of large and complex cases.’

‘Andy Brown is tactically astute, steadfast in his representation of his clients’ best interests.’

Chris Young combines meticulous case preparation with a personable approach.’

Principaux clients

B&M Retail


W F & L Limited


Push Energy


CVR Global Offshore Limited


Principaux dossiers


  • Advising a multinational leader in advertising technology and programmatic media trading on resolving its global tax risks with an estimated value of $111 million.
  • Defending 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 an IT business into potential bribery, tax irregularities and money laundering.

Kuit Steinart Levy LLP

Praised by clients for its 'integrity, responsiveness, and professionalism', Kuit Steinart Levy LLP boasts a team skilled in both civil and criminal tax matters, with a particular strength in advising clients on the disclosure of offshore-held funds. The team is led by the 'impressive' Robert Levy, renowned internationally for his expertise in representing individuals under investigation for tax-related issues, including serious fraud. Paul Bricknell plays a key role in tax disclosure cases, while dispute resolution consultant Wendi Bussin - noted for her 'great legal knowledge' and 'excellent client skills' - focuses on regulatory issues and business crime.

Responsables de la pratique:

Robert Levy


Autres avocats clés:

Paul Bricknell; Wendi Bussin


Les références

‘Lead partner was hands-on and did not delegate important pieces of work to junior team members.’

‘Integrity, responsiveness, and professionalism.’

‘Kuits focuses on providing a personal touch, building close relationships with existing and potential clients. They are excellent at putting clients at ease, explaining each stage of the process and likely outcomes.’

Principaux dossiers


Mishcon de Reya LLP

Mishcon de Reya LLP‘s practice works within the firm’s larger dispute resolution offering, with the support of the fraud, insolvency, and white-collar crime teams. The group is particularly active in ADR and mediation. Robert Hartley leads the team, and covers both direct and indirect tax disputes.

Responsables de la pratique:

Robert Hartley


Autres avocats clés:

Tabassum Khan; Julius Berling; Cathal McLoughlin


Principaux dossiers


Osborne Clarke LLP

Osborne Clarke LLP specialises in tax disputes in the technology industry, handling a range of complex matters, including cases with international elements. Highly experienced team lead Ian Hyde ‘is very bright and knowledgeable’, with expertise in litigation and arbitration, in addition to investigations and risk management. Alongside Hyde in the department are Frances Lewis, who is highly experienced in issues relating to employment tax, and Jack Prytherch, who joined from CMS in February 2024.

Responsables de la pratique:

Ian Hyde


Autres avocats clés:

Frances Lewis; Katherine King; Jack Prytherch


Les références

‘Ian Hyde and his disputes team are all very bright and knowledgeable. They have great insight into the tribunals and are very technically minded.’

‘Ian Hyde is very bright and knowledgeable. He has great insight into the tribunals and is very technically minded.’

‘From start to finish, they provided professional and consistent support in handling a range of matters. They have a sufficient understanding of the tax law climate, and approach work with a good sense of expertise.’

‘They take the time to listen to concerns, analyse the situation, and develop a strategic plan to address the issues at hand. Their understanding of the specific matter at hand was excellent, and they are skilled at advocating for their clients’ best interests.’

Principaux clients

Meta


Churchill Knight


Domino’s Pizza Group PLC


Veezu


Bolt


Principaux dossiers


Penningtons Manches Cooper LLP

Penningtons Manches Cooper LLP is active for domestic and international clients facing tax litigation, investigations, and enquiries. Kamran Rehman leads the group alongside James d’Aquino, who specialises in advising UHNWI in complex tax matters. Richard Marshall is a key name, with particular expertise in international tax matters.

Responsables de la pratique:

Kamran Rehman; James d’Aquino


Autres avocats clés:

Richard Marshall; Alex Fox


Les références

‘A great contentious trusts team and an excellent non-contentious private client team have joined forces to pioneer a new approach to tax litigation.’

‘Very user-friendly. Great teamwork. A joy to work with.’

‘Alex Fox is very calm and assured, and very able.’

Principaux clients

Eye-Chitecture


Principaux dossiers


  • Acting for the trustee in the bankruptcy of Alpha Insurance A/S and Qudos INsurance A/S.
  • Acting for the seller of Eye-Chitecture in relation to a claim brought under the SPA by the purchaser.
  • Advising a client alleged to be involved in a dividend ‘cum-ex’ type fraud committed against the Danish tax authorities.

Stephenson Harwood

Stephenson Harwood is active for corporate clients and individuals facing high value tax disputes, frequently with an international element. The group regularly provides tax risk advice, aiding clients with complex multijurisdictional tax planning. John Meehan leads the team. Shofiq Miah is a key name, advising on a broad range of corporate and indirect tax disputes.

Responsables de la pratique:

John Meehan


Autres avocats clés:

Shofiq Miah


Principaux clients

BDO LLP


Manolete Partners PLC


Principaux dossiers


  • Defending our client accountancy firm BDO LLP in multi-defendant high court proceedings against a professional negligence claim relating to inheritance tax planning of a former client’s c.£6 million estate.
  • Advising Matthew Tait, Malcolm Cohen and Manolete Partners PLC on all matters arising out of the insolvency of Bell Pottinger LLP.