Tax disputes are increasingly common in the current climate, and will probably continue to rise.
We are used to dealing with tax enquiries and disputes, and endeavour to negotiate an outcome satisfactory to all wherever possible. If this is not possible, however, we are able to assist clients through tax litigation and have recently been involved in some high profile cases (including a £50m corporate tax residency dispute).
As a team we have experience of working on one of HMRC’s pilot alternative dispute resolution (“ADR”) cases. Such ADR pilots for disputes are a new departure for HMRC and are similar to the mediation process used in civil cases. However, unlike the appointment of an independent mediator, the ADR pilot cases involve the appointment of a “facilitator" from within HMRC who has no prior involvement with the case. The pilot ADR process has now been rolled out nationwide.