Tax Disputes

Practice overview

We are one of the few City law firms to have a dedicated tax disputes and investigations practice, with our disputes lawyers working alongside subject matter experts, transfer pricing specialists and accountants from across our wider Corporate Tax group in the UK and internationally.

We assist clients with tax enquiries and appear regularly in appeal proceedings before the Tax Tribunals and in claims for judicial review. The team has experience litigating at every level of the court system (including before the Court of Appeal, Supreme Court and European Court of Justice) and has acted on some of the leading cases across the fields of corporate taxes, transfer pricing, partnership taxation, employment taxes, VAT, environmental taxes and tax procedure. We also act in tax-related commercial and professional disputes.

‘This is a truly excellent team. In depth expertise, excellent resourcing and a great collaborative spirit.’ - Legal 500 2025

‘One of the best tax litigation teams about. Deep experience of handling the most complex disputes with HMRC. Absolutely fantastic client care.’ - Legal 500 2025

Work highlights

Limited liability partnerships: Advising several asset managers and other clients in disputes with HMRC regarding the tax rules on 'mixed member partnerships', 'salaried members' and 'miscellaneous income', from providing support with HMRC enquiries through to representation in litigation.

Corporate taxes: We regularly carry out eDiscovery exercises for clients facing HMRC enquiries into loan relationships and other transactions where HMRC has asserted an 'unallowable purpose', represent clients in litigation against HMRC, and conduct ADR proceedings in this area.

Judicial review: Represented taxpayers in notable judicial review cases against HMRC including R(UBS AG) v HMRC [2024] UKUT 242 (TCC) and R(Rokos) v HMRC [2026] EWHC 733 (Admin).

International tax disputes: We acted for Burlington Loan Management DAC (Davidson Kempner Capital Management) in a multi-million pound tax treaty dispute arising out of the $7billion Lehman Brothers International (Europe) administration surplus. We were successful in the First-tier Tribunal and the Upper Tribunal [2024] UKUT 152 (TCC). The Court of Appeal’s judgment is pending.

VAT and financial services: Advising various financial institutions with HMRC enquiries into the application of the VAT exemptions for financial services to external and internal supplies of services.

Environmental taxes: We have acted for taxpayers in key cases concerning the operation of landfill tax: R(Veolia ES Landfill Ltd) v HMRC [2016] EWHC 1880 (Admin), HMRC v Devon Waste Management Ltd & Ors [2021] EWCA Civ 584, Augean North Ltd & Anor v HMRC [2021] UKFTT 230 (TC).

Tax related professional disputes: We act for clients in professional disputes against tax advisers and are experienced in managing sensitivities surrounding the interaction between professional liability claims and any parallel tax proceedings involving HMRC.