Our team can assist you on the full range of tax disputes with HMRC, including: 

  • Acting for groups of taxpayers with similar issues against both HMRC and commercial parties under the High Court procedure known as Group Litigation Orders (GLOs) and under the Tax Tribunal procedures for lead and representative cases
  • Challenging HMRC assessments and determinations in the First-tier Tax Tribunal, Upper Tribunal, Appellate, and European Courts in relation to the full range of taxes, including income tax, capital gains tax, corporation tax, VAT, stamp duty, and environmental taxes
  • Providing focused solutions in high-value, complex tax enquiries, often where previous attempts to resolve the enquiry have failed to reach a satisfactory result
  • Advising clients in relation to settling their tax disputes with HMRC, both settlements tailored specifically for clients, and on the impact on clients of non-negotiated HMRC settlement opportunities made to classes of taxpayers
  • Acting for clients who have received or expect to receive a HMRC Advanced Payment Notice (APN) or Follower Notice
  • Tax procedural challenges concerning whether HMRC has met the statutory criteria when assessing taxpayers. This often arises when HMRC misses time limits and raise discovery assessments
  • Challenges against statutory information notices and disputes concerning whether documents and advice is privileged from disclosure to HMRC or third parties
  • HMRC sponsored Alternative Dispute Resolution, including mediation, High Risk Corporates Programme (HRCP), Managing Complex Risk (MCR) and HMRC Mediations
  • Challenging tax legislation and certain tax liabilities on the grounds that they are contrary to EU law
  • Restitution claims against HMRC in the High Court for recovery of overpaid taxes (including High Court claims in relation to the various EU Group Litigation Orders)
  • Judicial review, for example, in relation to HMRC’s discretion to extend certain time limits, general unfairness and claims in relation to HMRC failure to abide by its own guidance.

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

Meet the Tax Litigation 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”. 

David Pickstone, Partner, Head of Tax Litigation, Stewarts