Tax Litigation & Investigations

BCL 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.

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Our team have a robust knowledge and experience in dealing with investigations concerning 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 litigation & investigations 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 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 taxpayers and third parties in receipt of Schedule 36 information notices and advising on responding to or appealing such notices.
  • 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 companies by conducting internal investigations into the conduct of employees and directors
  • 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
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