Our tax investigations team is led by tax directors Lisa Vanderheide and Sarah Stenton, both experts in resolving complex tax enquiries and disputes with HMRC across the full range of taxes.

Our team can assist you in providing advice, strategy and solutions for high value, complex tax enquiries into individuals, owner managed businesses, partnerships and corporates. The typical cases we advise on are:

  • Suspected fraud enquiries carried out by HMRC’s Fraud Investigation Service under Code of Practice 9 (working together with our Financial Crime team, where appropriate)
  • Enquiries carried out by HMRC’s Fraud Investigation Service under Code of Practice 8. These are typically complex technical civil enquiries where Code of Practice 9 is not deemed suitable
  • Complex enquiries carried out by local HMRC offices, including corporate “cross-tax” enquiries (income tax, PAYE, VAT, inheritance tax and capital gains tax)
  • Employer compliance (PAYE) reviews undertaken by HMRC’s employer compliance team

The team can also review a client’s current and historic participation in marketed tax avoidance schemes. We advise on the options available using our up to date and detailed knowledge of HMRC Counter Avoidance Directorate policies.

We also advise on other tax avoidance issues including:

  • Accelerated Payment Notices
  • Follower Notices
  • The Serial Tax Avoiders Regime
  • Disguised remuneration paid via employee benefit trusts (EBTs) and contractor loan schemes
  • The 2019 “loan charge”
  • Settlement with HMRC including deferred payment arrangements

The team can assist with other HMRC related issues including:

  • Providing advice and assistance with overpayment relief claims
  • Facilitating and voluntary disclosures to HMRC where UK and/or offshore income, profits or gains have been overlooked
  • Challenging the legitimacy of HMRC discovery assessments, penalties, information and document requests and other inappropriate HMRC decisions, where necessary working with our Tax Litigation team

If you require assistance, please contact us or request a call from one of our lawyers.

Meet the Tax Litigation and Investigations team

Our specialist team is described by The Legal 500 as standing out for “its wealth of experience and strong team of very impressive lawyers”. 

Victor Cramer, Partner, Tax Litigation, Stewarts