Tax Investigations & Litigation
Any successful organisation or individual may face an investigation by HM Revenue & Customs exercising its broad range of civil or criminal investigative powers. In addition, HMRC is increasingly using insolvency legislation to seek to recover tax losses.
We are recognised as being at the forefront of firms that specialise in assisting clients in cases involving allegations of white collar crime and tax fraud, and in tax investigations. Our civil litigation department complements that expertise, with many of the cases in which we are instructed involving allegations of fraud, and we are ideally placed to help clients with cases that involve litigation in the criminal and civil courts simultaneously. Much of our work involves multi-million pound claims and we often assemble teams of leading barristers and international accountancy practices tailored to the requirements of each particular case.
We represent claimants and defendants in resolving disputes in all areas of commercial litigation; whether negotiating a settlement of a tax investigation or pursuing a claim from the obtaining of a freezing injunction to the enforcement of a judgment.
Increasingly, arguably as part of sending a deterrent message, HMRC is tending to allege criminal fraud in addition to the use of the civil courts when alleging tax avoidance, as opposed to legitimate tax planning. We are particularly experienced in this area and readily understand the most complex sets of tax planning arrangements in their proper context, which can give our clients a significant advantage when dealing with HMRC.
Our team is experienced in civil fraud, tax litigation, insolvency, trusts, assets tracing in multiple jurisdictions and judicial review. We are also experienced in the enforcement of foreign judgments in the UK courts and in the enforcement of domestic judgments abroad. In addition, in recognition that civil litigation can be lengthy and expensive, we aim to conclude litigation at an early stage wherever possible and, if it is in our client’s best interests, we are always prepared to explore the possibility of a negotiated settlement.