Efficient, sensible and highly intelligent lawyers, and top-quality litigation strategists.
The tax disputes team at Penningtons Manches Cooper brings our cross-practice expertise together in a cohesive group. We advise a range of domestic and international clients on all areas of potential and active tax disputes, both in the UK and internationally. As well as representing individuals, fiduciaries and corporate entities, we act in relation to trusts and estates.
Our work encompasses tax litigation, investigation and enquiry cases. We assist clients in making voluntary disclosures to HM Revenue & Customs (HMRC) to regularise their tax affairs, whether that be through the use of a particular, targeted disclosure facility or otherwise. We are also engaged on professional negligence claims in respect of tax matters, and other claims or disputes which include elements of tax or tax consequence. Whatever the nature of the dispute, by becoming involved at an early stage and by providing bespoke advice, we are able to offer support and solutions to manage the outcome.
We act on disputes and disclosures relating to a broad range of taxes, from VAT and stamp duty land tax to remuneration and termination packages, including IR35 issues, as well as income tax, capital gains tax, inheritance tax and the annual tax on enveloped dwellings. These call on the skills of our specialist tax and dispute resolution lawyers who are highly regarded in their respective fields. Drawing on expertise from across the firm, we work collaboratively to deliver a comprehensive and tailored offering to our clients.
The team also provides an accounting and tax compliance service to individuals, trustees and executors. Our experience and depth of expertise proves invaluable to clients allowing all elements of an investigation to be undertaken ‘in-house’, where appropriate. In addition to tax disclosures, we are regularly engaged to deal with the accounting matters that are a necessary part of handling many disputes.
We also work collaboratively with our clients’ wider advisory teams – including accountants, non-UK tax advisors, family offices and fiduciaries - and with external tax counsel. Our team includes members of the Association of Contentious Trusts and Probate Specialists, the Society of Trust and Estate Practitioners, the Chartered Institute of Taxation and the International Bar Association.
Advising the trustee of a settlement on enquiries by HMRC into two high value claims for tax relief. The dispute centred principally on the interpretation of tax legislation and public law arguments based on legitimate expectation.
Acting for a German company and its director in relation to a claim against them, and multiple other defendants, by the Danish tax authorities. The action centred on allegations of fraud to obtain Danish withholding tax relief. The case was disposed of on grounds of jurisdiction and has been widely reported.
Successfully agreeing disclosures under the worldwide disclosure facility for overseas trusts in relation to historic inheritance tax liabilities. These were challenging due to a lack of historic records.