Tax Disputes

Our experienced tax dispute solicitors help businesses, individuals and professional advisers resolve conflicts with HMRC. From challenging unexpected tax assessments and penalties to negotiating settlements and handling tribunal appeals, we provide clear, practical advice to protect your position and minimise disruption.

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Key contact

Nathan Talbott

Nathan Talbott

I advise corporates, individuals and financial institutions on a range of litigation and tax issues. I also advise FCA-regulated firms in relation to commercial disputes, misconduct, regulatory and enforcement action.

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Meet the team

Resolving your tax disputes

We advise on disputes involving (amongst others):

  • Corporation Tax
  • Capital Gains Tax
  • Income Tax
  • PAYE Tax
  • National Insurance Contributions
  • Inheritance Tax.

Our experience

We are experienced and expert at resolving HMRC disputes. We do this through:

  • Early engagement with HMRC to limit penalties and interest
  • Negotiation of settlements where appropriate
  • Preparation of appeals and representation at tribunal hearings
  • Protecting reputations where businesses or individuals are facing allegations of misconduct
  • Providing practical, commercial advice to help you move forward with confidence.

Frequently asked questions on tax disputes

We regularly advise on tax disputes in relation to (amongst others):

  • Employee Benefit Trusts (EBT)
  • Employer-Financed Retirement Benefits Scheme (EFRB)
  • Tax Reliefs (Including: Entrepreneurs Relief, Incorporation Relief, Roll Over Relief, R&D Relief, Marginal Relief, Disincorporation Relief and Terminal Loss Relief)
  • Enterprise Investment Schemes (EIS)
  • Stamp Duty Land Tax Schemes (SDLT)
  • Share Loss Relief Schemes
  • Car Benefit Schemes
  • Employee Bonus Schemes – Growth Securities Ownership Plan (GSOP) and other avoidance schemes based on contracts for difference
  • Film Fund Schemes.

Under the Finance Act 2014, HMRC can  demand payment on account of a tax advantage received from participating in a tax avoidance scheme, prior to any final determination of the legitimacy of the tax avoidance scheme.

An APN can be issued by HMRC if a taxpayer has received a tax advantage from participating in a scheme; HMRC has an open enquiry or appeal into that tax advantage; and the scheme in question has been declared as a tax avoidance scheme under DOTAS (disclosure of tax avoidance schemes).

If you have received an APN it is imperative that you seek legal advice.

Seek legal advice immediately. Early engagement can often stop a dispute from escalating and may help reduce penalties and interest.

Yes. Options include requesting an internal HMRC review, lodging a formal appeal or taking your case to the Tax Tribunal. We guide clients through each stage of the process.

Services from our Dispute Resolution team

Recognition of our work

Investors in People

Investors in People

Legal 500 2026 – Top Tier Firm

Legal 500 2026 – Top Tier Firm

Legal updates and thought leadership

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Hear what our clients say about us

Stewart is very smart; it’s always a pleasure working with him. He is always thinking about the strategic considerations of a case.

Client testimonial Chambers 2026

Natalie is a very good litigator who is very dedicated to her clients and incredibly hard-working.

Client testimonial Chambers 2026

Kate continues to provide an excellent service. She combines a strong knowledge base with an excellent understanding of what clients are seeking to achieve.

Client testimonial Chambers 2026

Elizabeth Beatty is very well respected when it comes to large shareholder disputes. She is trusted by clients and judges and respected by opponents.

Client testimonial Chambers 2026

Dominic Hopkins is simply an excellent lawyer – reassuringly old-school and extremely commercially astute.

Client testimonial Chambers 2026

Ben is very sound, very solid, very thorough and a safe pair of hands.

Client testimonial Chambers 2026

Andrew is a very experienced individual with a great breadth and depth of knowledge. He is always personable and focused on getting results for the client.

Client testimonial Chambers 2026

Adam Finch always has a strong grip on matters at every stage.

Client testimonial Chambers 2026

We would like to take this final opportunity to thank you for all your help, patience and advice in getting the matter successfully settled. You have always been there when we have been in need, with guidance, diplomacy and patience which has helped us so much. It has been a difficult time and such a relief that it is now settled.

Client testimonial Business dispute

We spent years looking for a team with the correct expertise, professionalism, drive and responsiveness to handle our complex legal matter and dispute. This team was exactly that. Had they not been instructed we likely wouldn’t have reached a resolution at all, never mind one that was thorough and legally sound.

Client testimonial Legal 500 2026

Natalie Minott is an exceptional lawyer with a unique set of skills that set her apart from most lawyers that I have ever come across. She is technically excellent, responsive, level headed and professional and has the drive and expertise to lead a dispute to an appropriate resolution that both takes the stress away from her clients and shows real value.

Client testimonial Legal 500 2026

Andrew Walker has been growing the team across the firm’s offices to become a more significant player in the property/real estate litigation market; their locations and team mean they are able to offer a good balance between expertise and cost efficiency.

Client testimonial Legal 500 2026

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