go to the homepage skip to main navigation skip to content area
Berwin Leighton Paisner logo

Select international office

Please select...
Lawyer Directory

By Expertise

Practice areas:

Contentious Tax

loading, please wait...

Corporates and private individuals are facing increased scrutiny from HMRC which, like tax authorities around the world, is seeking to maximise its tax revenue and protect its tax base from non-compliance. HMRC has invested heavily in tackling non-compliance over the last few years and it is clear that the battle is set to intensify.

Closing the ‘tax gap’ - the difference between the tax collected and the tax, which in HMRC’s view, should be collected - is seen as an important part of the drive to cut the UK’s budget deficit. HMRC’s definition of the tax gap includes all tax which in HMRC’s view should have been collected - this can include tax not paid through legitimate planning techniques.

HMRC's approach to corporate taxpayers has been undergoing significant changes. These changes, which include HMRC publishing their approach to compliance and risk management for large businesses; focusing resources on those corporates perceived by HMRC as contributing to the 'tax gap'; and recent accounting requirements on corporates to document risk, have encouraged tax directors to think pre-emptively. HMRC have also introduced a Litigation and Settlement Strategy. As a result, litigation has increased in the new Tax Tribunals, the Higher Courts and the European Court of Justice. 

As well as tackling non-compliance, HMRC is challenging claims in areas of ambiguity, such as residence and domicile, with increased vigour. We have extensive experience of advising on the issues involved and negotiating with HMRC. We help individuals deal with tax authority investigations into their personal or business affairs advising on the legal and tax issues, how to deal with revenue enquiries, disclosure of information, strategy, reputation risk management and how to mitigate any tax liability. We also advise individuals who wish to regularise their tax affairs through voluntary disclosure.

Our specialist contentious tax team provides a unique multi-disciplinary service. Working within the wider Tax, VAT & Private Client groups, the contentious tax team offers a comprehensive service covering strategic advice on the whole range of risk issues, formal enquiries and investigations by HMRC, voluntary disclosure and litigation at Tribunal level, in the Higher Courts and the European Court of Justice.

Get in touch

contact thumbnail

Liesl Fichardt

BLP
Partner, Corporate Tax
contact thumbnail

Andrew Watters

BLP
Director, Corporate Tax

If you need help with a legal or business issue, please contact our team.