Tax litigation experience

  • Tax fraud - advising senior executives of a substantial UK building society in relation to an investigation into tax fraud by HMRC.
  • Negligent tax advice - advised a PLC on claims against a firm of tax advisors for approximately US$100 million  arising out of multi-jurisdictional tax advice.
  • Big Four accountancy practice - regularly act for this accountancy practice in relation to advising on and defending claims of allegedly negligent tax advice.
  • Raid by HMRC - advised and attended a raid by HMRC on the premises of an accountant.
  • Indofood International - advised the claimants up to the Court of Appeal and winning in Indofood International Finance Ltd v JP Morgan Chase Bank NA London Branch [2006] STC 1195.
  • Capital allowance dispute - advised an infrastructure company in a capital allowance dispute against HMRC and acting for the company at Special Commissioners.
  • Investment trust - advised a listed investment trust on liabilities and claims in connection with tax exposures arising from the use of structured treasury products and risks to its investment trust status.
  • Cases on appeal - advising in cases on appeal to the Special Commissioner, High Court, Court of Appeal and House of Lords.
  • Disputes with HMRC - advised on a number of high-value disputes with HMRC involving leasing structures and the ability of our clients to claim capital allowances.
  • Group payment arrangement - negotiated the final resolution to a dispute with HMRC in relation to a Group Payment Arrangement involving a major insurance group and its broking arm.
  • Transfer pricing assessments - defended against transfer-pricing assessments in the oil and gas, shipping and real estate sectors.
  • Tribunal representation - appeared in VAT tribunals on behalf of clients.
  • Tax indemnities - advised a number of lessees on their potential liability under tax indemnities to the finance lessor.
  • Private bank - advised on its customers’ potential claims arising from the failure of a tax avoidance scheme created by a global financial institution.
  • Real estate investment company - advised on liabilities and claims in connection with a capital loss scheme.
  • Tax investigation - advised senior management of a well-known financial institution in a criminal and civil investigation being conducted by HMRC, including PACE interviews under caution.

Enthusiastic and always ready to

Chambers UK 2010

"SH are the closest thing to having an extended in-house legal team. Their commercial advice fits seamlessly into our business."

Chambers UK 2012

"It's the teamwork which impresses most. It's a seamless and effective operation and there's no other team I'd rather work with."

Chambers Asia-Pacific 2012

"A fabulous presence in Asia"

Legal 500 UK 2012