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Tax Disputes

Our niche team of tax litigation solicitors specialise in high value and complex tax and financial products litigation.

We advise clients faced by demands from HMRC on methods to minimise exposure and also bring claims against professionals who have negligently “sold” the product to the client.

"They are brilliant - very friendly, very quick, and very open with their costings."

Chambers UK

litigation funding

Funding

Some litigants apply for litigation funding to pay their legal costs because without it they would not be able to afford to pursue an action at all. But this is not the only situation in which litigants seek to use litigation funding.

Businesses no longer need to invest and risk their own capital to fund a legal claim.  FISCUS is the funding package that we can offer clients to help manage the financial risk of litigation and move those costs off your balance sheet. 

Find out more about litigation funding options available to you.

We advise on disputes involving (amongst others):

  • Corporation Tax;
  • Capital Gains Tax;
  • Income Tax;
  • PAYE tax;
  • National Insurance Contributions; and
  • Inheritance Tax.

We regularly advise in relation to (amongst others):

  • Employee Benefit Trusts (EBT);
  • Employer-Financed Retirement Benefits Scheme (EFRB);
  • Tax Reliefs (Including: Entrepreneurs Relief, Incorporation Relief, Roll Over Relief, R&D Relief, Marginal Relief, Disincorporation Relief and Terminal Loss Relief);
  • Enterprise Investment Schemes (EIS);
  • Stamp Duty Land Tax Schemes (SDLT);
  • Share Loss Relief Schemes;
  • Car Benefit Schemes;
  • Employee Bonus Schemes - Growth Securities Ownership Plan (GSOP) and other avoidance schemes based on contracts for difference; and
  • Film Fund Schemes.

Accelerated payment notice (APN)

Under the Finance Act 2014, HMRC can now demand payment on account of a tax advantage received from participating in a tax avoidance scheme, prior to any final determination of the legitimacy of the tax avoidance scheme.

An APN can be issued by HMRC if a taxpayer has received a tax advantage from participating in a scheme; HMRC has an open enquiry or appeal into that tax advantage; and the scheme in question has been declared as a tax avoidance scheme under DOTAS (disclosure of tax avoidance schemes). 

If you have received an APN it is imperative that you seek legal advice.

Matters we are currently advising on include:

  • A multi-million pound claim by HMRC against a limited company relating the establishment of employee benefit trusts (EBT) and employer funded retirement benefit schemes (EFRBS);
  • The impact and enforceability of APNs on businesses and individuals;
  • We act for numerous individuals who advised to enter into film partnerships;
  • A mis-sold Employee Bonus Scheme based on contract for differences resulting in a £20M+ demand from HMRC;
  • Negligent financial advice relating to pensions;
  • Claims where advisers have failed to invest according to the client’s attitude to risk; and
  • Incorrectly executed schemes resulting in an inability to claim the tax relief intended.

Recent articles

July 14th, 2020 Guide to Judicial Review, The Loan Charge Review and HMRC

Have you repaid loans as a result of HMRC’s Guidance pre-Loan Charge Review that you would no longer be liable for the L...

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May 1st, 2020 Tax Schemes to avoid the Loan Charge

This article sets out an example of the types of schemes that we are seeing, how we expect HMRC will treat these schemes...

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April 16th, 2020 A guide to disclosure under the disclosure pilot

Disclosure involves identifying and making available documents that are relevant to the issues in dispute to the other p...

Read article
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