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Tax Dispute Resolution

The Litigation and Settlement Strategy, the Tax Tribunals system and the increasing influence of EU law on the operations and activities of businesses in the UK make it important for you to understand the role that tax dispute resolution might play in your business.

It’s important when planning a transaction or implementing a new business structure, to consider the risk of challenge by HMRC from the outset. We can help you reduce the risk of an HMRC enquiry or challenge e.g. ensuring that the commercial reasons for the transaction are clearly set out and recorded in writing, that implementation is thorough and complete and that all of the relevant documents are retained.

If your business becomes the subject of an HMRC enquiry you may need help in dealing with requests for information, closure notices and assessments and correspondence.

Our team brings together highly experienced individuals with extensive experience in providing advice to your business when a dispute arises whatever industry sector you may be in. Our primary objective is to help our clients to prevent disputes with HMRC wherever possible. If a dispute is unavoidable, we will help you to resolve it as quickly and efficiently as possible. The specialisms within dispute resolution are:

Issues and trends

  • Resolution: A new approach to dispute resolution
    Resolution is back with a vibrant new look and examines HMRC’s recently refreshed Litigation and Settlement Strategy and the impact on the use of alternative dispute resolution to resolve tax disputes.
  • UK/Swiss Tax Agreement – 24 August 2011
    Following a previous declaration made on 25 October 2010, an agreement was reached on 24 August 2011 between the UK Treasury and Swiss Federal Department of Finance regarding the treatment of Swiss accounts held by UK taxpayers.
  • Can you make a protective claim for overpaid Stamp Duty Reserve Tax?
    In the wake of the recent ECJ case involving HSBC which held that the levying of the 1.5% stamp duty reserve tax on companies issuing new shares into depositories such as American Depository Receipts was unlawful under EC law, companies may be due a refund of the SDRT wrongly paid. Find out what this may mean for your business by reading our full briefing publication.

Our solutions

We can:

  • Assist you in your transactions, advising on the likely risk of challenge from the initial structuring and planning stages through to the final implementation. We can carry out a post-implementation review to ensure that things have all been done in accordance with appropriate rules and regulations.
  • Advise you on how best to deal with HMRC requests for information and any potential enquiries that they may raise.
  • Help you obtain closure notices and appealable decisions where appropriate.
  • Help you put your best arguments forward to help resolve disputes under the new independent review process.
  • Assist you in working closely with HMRC in an attempt to reach mutually acceptable settlements without recourse to litigation if possible.
  • Represent you at both the First-tier Tribunal and Upper Tribunal and we can guide you through the courts.

Useful links

  • Tax careers
  • Submit a request for proposal
  • Contact us

Highlights

  • Alternative Dispute Resolution
    Mediation and Tax Disputes
  • The Rank Group Plc
    The Rank Group Plc has won its case at the Court of Justice of the European Union (CJEU) successfully demonstrating that the fiscal treatment of certain supplies of gambling contravened the EC principle of fiscal neutrality. This was a significant win for Deloitte.

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