When tax disputes with HMRC or international tax authorities cannot be resolved through engagement or negotiation, clients need to prepare for litigation. The key is recognising that point early and managing each step with that endpoint in mind. We act for clients in UK and international tax litigation, from initial assessment through to Tribunal proceedings, appeals and, where appropriate, judicial review.

Our approach

We assess from the outset how issues are likely to be determined in litigation, including the legal framework, the factual questions that will matter and the evidence required to support the position. That analysis informs how the case is presented from an early stage, ensuring consistency between correspondence, evidence and litigation strategy.

Many disputes turn on how established principles apply to complex or modern commercial arrangements. We are frequently instructed on matters where the law is developing or uncertain, including cases that contribute to the evolution of precedent.

Our tax litigation work

We act across a wide range of taxes and sectors, including VAT and indirect taxes, environmental taxes, corporate and international tax matters and disputes involving cross‑border issues or multiple jurisdictions. We are also instructed on commercial disputes and professional negligence claims where tax issues are central.

Where disputes involve international elements, we work with in‑jurisdiction counsel to coordinate strategy, evidence and process, ensuring consistency across jurisdictions and effective management of procedural requirements.

Litigation readiness and evidence

Tax litigation is often determined by the quality of the evidence. We work with clients to assess the factual record, identify evidential gaps and strengthen documentation and audit trails at an early stage. We undertake formal disclosure exercises, data reviews and e‑discovery processes.

When we are instructed

We are typically instructed where:

• a dispute has reached, or is expected to reach, Tribunal proceedings or appeal;
• prolonged engagement with HMRC has reached an impasse;
• after extended engagement with HMRC by existing advisers, a more decisive approach is required;
• there is material financial exposure or reputational risk;
• technical or factual issues are complex or uncertain; or
• the case raises issues of wider principle or evolving case law.

How we help

We assist clients with:

• representing clients in tax litigation before the Tribunals and courts;
• developing litigation strategy and assessing prospects;
• shaping correspondence and submissions with litigation in mind;
• managing evidence, disclosure and e‑discovery;
• engaging with HMRC and other tax authorities;
• judicial review and appellate strategy; and
• litigating tax‑related commercial disputes and professional negligence claims.

Contact us

If you need representation or advice in tax litigation, or want to sense check your position in an existing case, please contact us to discuss.