Tax and Structuring Other services Services Insights People Get in touch Main Navigation People Sectors Services Insights Client Solutions About Us Locations Tax Disputes and Investigations We are a leading team of tax litigation and investigations specialists advising in respect of all taxes and duties. Why choose our Tax Disputes and Investigations lawyers? We advise individuals and companies on all aspects of investigations and enquiries undertaken by HMRC. The vast majority of disputes on which we are instructed settle, often on advantageous terms for our clients. Where settlement cannot be achieved, we litigate and have an excellent success record, from the Tribunals up to the Supreme Court. We advise on cross-border tax issues, particularly in the EU, and have had conduct of many references to the CJEU. We are multi-lingual, advising in English, French, and German. In conjunction with our network of European offices, we advise clients on tax matters in France, Germany, Italy, Luxembourg and Spain. We are consistently highly-ranked in Chambers and Legal 500 and have more ranked contentious tax partners than any other firm in the UK. Clients praise us for our technical and procedural expertise, commerciality, and understanding of their business needs. We also offer a range of funding options for contentious tax clients, including fixed fees and contingent arrangements. Notable Cases and Work Autogas (Europe) Ltd v Ochocki [2018] 9 WLUK 72. Successful defence of a multi-million pound claim brought by a liquidator that alleged knowing assistance in a VAT fraud committed against HMRC. R, on the application of Vacation Rentals (UK) Limited v HM Revenue and Customs [2019] STC 251. Successful judicial review that prescribes the parameters of when taxpayers can rely on HMRC's published guidance. The Commissioners for HM Revenue and Customs v Desmond Higgins [2019] STC 2312. The team acted for Mr. Higgins at the First-tier Tribunal, Upper Tribunal and Court of Appeal, resulting in him succeeding in his claim for Principal Private Residence Relief. The decision clarifies that the relief is available for the period between exchange and completion. The Commissioners for HM Revenue and Customs v Invamed Group Limited and Others (C-198/15). Representative group litigation on behalf of a consortium of mobility scooter companies that is developing customs duty law in this area across the EU. The CJEU's decision in the group's favour was released in May 2016. The decision of the Court of Appeal in the group's favour was released in February 2020. Most of our matters are settled without recourse to the courts and remain confidential. Recent examples of such work, and current matters, include: Settlement of a claim against a US law firm for fraudulent misrepresentation in respect of a tax geared investment structure Appeals against HMRC's imposition of tax charges in respect of "tax avoidance schemes" Advising in respect of Accelerated Payment Notices and Follower Notices Development of a virtual LLP concept that is enabling well over 1,000 investors in film structures to participate in representative appeals to the First-tier Tribunal Advising businesses and individuals in relation to IR35 Advising SRA and FCA regulated individuals in relation to COP8 and COP9 investigations into their personal tax affairs Advising on and conducting tax-related professional negligence claims Assisting businesses during HMRC searches under warrant at their offices. Assisting (including at interviews under caution) individuals who have been accused of cheating the public revenue Key contacts PARTNER, DISPUTE RESOLUTION Philippe Freund London, England +44 (0)330 460 7046 Email Philippe DISPUTE RESOLUTION TAX DISPUTES AND INVESTIGATIONS TAX LITIGATION PARTNER, CO-HEAD OF TAX DISPUTES AND INVESTIGATIONS George Gillham London, England +44 (0)330 460 7044 Email George TAX AND STRUCTURING TAX DISPUTES AND INVESTIGATIONS SEE FULL TEAM Latest tax disputes and investigations news and views PRESS RELEASE Fieldfisher secures landmark £1.6 billion settlement offer from HMR... 06/09/2021 INSIGHT Up to £45 million of 'Follower Notice' penalties liable to be repai... 06/09/2021 INSIGHT Disguised Remuneration Repayment Scheme – No redress? Matthew Sharp & Siobhan Gillespie 26/08/2021 INSIGHT Finding the end user in IR35 supply chains Matthew Sharp & Christopher Kientzler 30/06/2021 Sign up to our email digest Click to subscribe or manage your email preferences SUBSCRIBE Manage Email Preferences OTHER FIELDFISHER SITES Terms of Business Terms and Conditions Legal Notice Privacy Notice Cookie Notice Modern Slavery Careers Recruitment Terms of Business Accessibility Complaints Procedures Fieldfisher Capital Legal Notices © Fieldfisher 2021 We use cookies to provide website functionality, to analyse our traffic, and to enable social media functionality. Our Cookie Notice provides more information and explains how to amend your cookie settings. View our Cookie Notice Cookies Settings Reject All Accept All Cookies