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Tax Disputes and Investigations

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The global tax landscape has undergone radical change in recent years.  In the face of growing pressure to crack down on perceived tax avoidance by multinationals and high net worth individuals, tax authorities including HMRC are becoming increasingly proactive.  All taxpayers now face an increasingly complex and hostile environment, with unprecedented levels of scrutiny over their tax affairs.

Against this backdrop, tax disputes are on the rise and can cause both financial loss and reputational harm.

Why use CMS for Tax Disputes and Investigations 

As part of the CMS global network with tax capability in over 70 offices, the CMS Tax Disputes & Investigations team is well-placed to advise on all forms of (direct and indirect) contentious tax matters.  

Our dedicated specialists have a wealth of experience guiding both individuals and corporates (across a wide range of sectors) through all aspects of tax dispute prevention, management and resolution.

Areas of expertise

Work undertaken by the CMS Tax Disputes & Investigations team includes:

Contact the CMS Tax Disputes & Investigations team now for advice

Without proper management, even seemingly straightforward enquiries or compliance checks can quickly spiral out of control.  If you are concerned about an ongoing (or potential) tax dispute or investigation, please contact a member of our team as soon as possible to help protect your position.  

Aside from tax disputes and investigations, CMS can also help with wider tax services, as well as all other types of disputes and investigations.

Ad­vising the Board


UK Tax Dis­putes Di­gest
Wel­come to the au­tumn 2022 edi­tion of our UK Tax Dis­putes Di­gest: a high-level sum­mary for heads of tax, fin­ance dir­ect­ors, gen­er­al coun­sel and oth­er in-house pro­fes­sion­als of key de­vel­op­ments in con­ten­tious...
Off­shore com­pan­ies own­ing UK prop­erty asked to cer­ti­fy their tax po­s­i­tion
HM­RC have star­ted is­su­ing nudge let­ters to off­shore com­pan­ies own­ing UK prop­erty who they be­lieve may have an out­stand­ing li­ab­il­ity to UK tax.  Re­cip­i­ents are asked to com­plete an en­closed “cer­ti­fic­ate...
New elec­tri­city gen­er­at­or levy in­tro­duced
The UK gov­ern­ment has an­nounced the in­tro­duc­tion of a wind­fall tax on cer­tain elec­tri­city gen­er­at­ors in the form of the ‘elec­tri­city gen­er­at­or levy’, a new 45% tax levied on ‘ex­traordin­ary re­turns’...
In­crease and ex­ten­sion of En­ergy Profits Levy
The UK gov­ern­ment has today an­nounced a 10% in­crease in the en­ergy profits levy ap­ply­ing to profits from UK oil and gas activ­it­ies, tak­ing it from 25% to 35%. The end date for the levy has also been ex­ten­ded...
Au­tumn State­ment 2022 – Key tax high­lights
Today’s Au­tumn State­ment was aimed at tack­ling the cost of liv­ing crisis and re­build­ing the eco­nomy, in the con­text of an ac­know­ledg­ment by the Chan­cel­lor that the UK is in re­ces­sion. Clearly, the tax...
UK Tax Dis­putes Di­gest
Wel­come to the sum­mer (and very first) edi­tion of our UK Tax Dis­putes Di­gest: a high-level sum­mary for gen­er­al coun­sel, heads of tax and oth­er in-house pro­fes­sion­als of some of the key tax cases over...
Di­ver­ted profits – UK Gov­ern­ment an­nounces le­gis­la­tion to coun­ter­act First-tier...
At the Au­tumn Budget 2021, the UK Gov­ern­ment an­nounced that le­gis­la­tion ap­plic­able to di­ver­ted profits tax (DPT) will be amended to make clear that cor­por­a­tion tax en­quir­ies can­not be closed dur­ing a...
Tax Risk Eval­u­ation and Mit­ig­a­tion Schemes
The tax cli­mate in the UK has changed sig­ni­fic­antly in re­cent years and HM­RC are in­creas­ingly likely to chal­lenge ar­range­ments they re­gard as ex­cess­ive tax plan­ning.  There are also in­creas­ing ob­lig­a­tions to dis­close in­form­a­tion about cer­tain trans­ac­tions or ar­range­ments as they arise, cre­at­ing fur­ther ad­min­is­trat­ive bur­den on all tax­pay­ers (in­clud­ing those who may not even be know­ingly en­ga­ging in tax avoid­ance).
Tax-re­lated (Com­mer­cial) Dis­putes
Tax dis­putes are not re­stric­ted to dis­putes with tax au­thor­it­ies.  Where un­ex­pec­ted tax li­ab­il­it­ies and pen­al­ties arise, tax­pay­ers will need to de­term­ine wheth­er they are able to re­cov­er any as­so­ci­ated losses from third parties (for ex­ample, un­der war­ranties and in­dem­nit­ies).
Vol­un­tary Tax Dis­clos­ures and Pen­alty Mit­ig­a­tion
Dis­cov­er­ing a po­ten­tial tax er­ror can be a wor­ry­ing time for any busi­ness or in­di­vidu­al.  In such cir­cum­stances, the best course of ac­tion is in­vari­ably to es­tab­lish the ex­tent of any er­rors be­fore mak­ing a vol­un­tary dis­clos­ure to the tax au­thor­ity.
Tax Of­fences and Ser­i­ous In­vest­ig­a­tions
HM­RC have powers to carry out both civil and crim­in­al in­vest­ig­a­tions in re­la­tion to UK taxes and, when de­cid­ing wheth­er to seek pro­sec­u­tion for cases in­volving dis­hon­esty or eva­sion, have a range of (stat­utory and com­mon law) of­fences at their dis­pos­al.  These of­fences ap­ply equally to both in­di­vidu­als and cor­por­ates.  The Crim­in­al Fin­ances Act 2017 (CFA) also es­tab­lished two new, strict li­ab­il­ity of­fences re­lated to the fa­cil­it­a­tion of eva­sion of UK and for­eign tax, mak­ing it is easi­er than ever for cor­por­ates to be pro­sec­uted.
HM­RC Civil In­form­a­tion Powers
HM­RC have a wide range of stat­utory powers at their dis­pos­al to in­vest­ig­ate the tax af­fairs of both busi­nesses and in­di­vidu­als.  This in­cludes the abil­ity to is­sue ‘in­form­a­tion no­tices’ in or­der to com­pel the shar­ing of in­form­a­tion or doc­u­ments re­quired for check­ing the tax po­s­i­tion of UK tax­pay­ers.