Tax Litigation and Investigations

BCL’s has extensive experience representing taxpayers in relation to enquiries and investigations opened by HMRC.  BCL’s tax team have a wealth of experience in advising on all aspects of contentious tax litigation and are able to provide expert advice in relation to both civil and criminal investigations.

Our team have a robust knowledge and experience in dealing with the full range of direct and indirect taxes and duties including:

  • Income Tax (PAYE & Self-Assessment)
  • National Insurance
  • Value Added Tax (VAT)
  • Capital Gains Tax
  • Inheritance Tax

BCL’s tax team has considerable experience in providing advice and representation in relation to:

  • Code of practice 8
  • Code of Practice 9
  • Statutory enquiries (section 9A TMA 1970 & section 12AC TMA 1970)
  • Information requests (Schedule 36 Finance Act 2008)
  • Production orders
  • Appeals to the First Tier Tribunal (Tax Chamber) and Upper Tribunal (Tax and Chancery Chamber)
  • Internal Investigations
  • Self-reports to HMRC
  • Insolvency proceedings brought by HMRC
  • Interviews under caution
  • Dawn raids

Our experience

  • Acting for taxpayers in relation disputes as to residence under both the statutory residence test (SRT) and common law.
  • Acting for taxpayers in relation to disputed foreign domicile.
  • Acting for a taxpayers in relation to Code of Practice 9 (COP 9) enquires where fraud is suspected.
  • Acting for taxpayers in Code of Practice 8 (COP 8) enquiries
  • Acting for companies by conducting internal investigations into the conduct of employees and directors
  • Acting for taxpayers and third parties in receipt of Schedule 36 information notices and advising on responding to or appealing such notices.
  • Acting for taxpayers appealing penalties imposed by HMRC
  • Acting for individuals and companies under criminal investigation by HMRC
  • Advising individuals and companies subject to a dawn raid by HMRC

BCL’s tax team has experience advising taxpayers and professional advisers in relation to ineffective tax avoidance schemes including those making use of the loan charge, investment relief, and R&D relief. 

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