Tax Investigations

Our leading tax investigations team has the experience and expertise to guide you through everything from a routine enquiry into a specific transaction to a coordinated dawn raid in multiple jurisdictions.

Tax authorities around the world are under increasing pressure to close the "tax gap" - the difference between the amount a tax authority thinks it should be collecting and the amount it actually collects. As a result, taxpayers' affairs are subject to an ever increasing level of scrutiny.

Undergoing a tax investigation can be a very stressful process for all those involved. The amounts at stake are often significant and, depending on the nature of the investigation, there may be the possibility of criminal sanctions or reputational damage.

We advise clients on:

  • large multi-faceted transfer pricing inquiries and investigations up to the final pre-trial stages
  • how information can best be provided to an overseas tax authority potentially conducting criminal investigations without losing privilege or breaching confidentiality obligations imposed by UK law
  • how to respond to raids by the UK tax authorities and how to deal with raids by overseas tax authorities already in progress in the UK
  • large scale interventions (or in-depth investigations) run over a number of years by the UK tax authorities

Partner Contacts

Peers... endorse [the team’s] ability to handle the most complex matters with ease Chambers UK, 2013

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Our key experience includes advising:

a global financial institution in relation to an investigation by HMRC into missing trader frauds in the carbon emissions market.

a major financial institution in relation to a dawn raid by HMRC under co-operation agreements with the tax authorities of another EU member state.

an international pharmaceuticals group in relation to an investigation by the SFO into alleged fraudulent invoicing and a related investigation by HMRC into alleged VAT evasion.

a group of senior employees from a major European financial institution on the regulatory and financial implications for the individuals of criminal allegations arising out of a very significant European tax investigation into a series of structured finance transactions.