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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

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30/11/2022
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...
Publication
22/08/2022
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...
Publication
25/10/2021
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).
Publication
25/10/2021
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).
Publication
25/10/2021
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.
Publication
25/10/2021
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.
Publication
25/10/2021
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.  
Publication
25/10/2021
HMRC Enquiries and Compliance Checks
HMRC investigations can take different forms depending on the issues involved.  HMRC generally use the term ‘compliance check’ to describe any investigation where they are seeking to verify that the correct amount of tax has been paid.  In the case of self-assessment returns, these checks are subject to strict legal procedures and properly referred to as ‘enquiries’. Without proper management, even seemingly straightforward enquiries and compliance checks can quickly spiral out of control.  If you are facing any type of investigation by HMRC, it is critical to seek appropriate professional advice as soon as possible.
Publication
25/10/2021
Tax Litigation and Alternative Dispute Resolution
If a taxpayer disagrees with a decision made by HMRC, in most cases a challenge may be brought by way of appeal or, for cases involving public law issues, by way of judicial review.  
Publication