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    KPMG Law

    Tax disputes and litigation

    Reduce the risk – and take control – of contentious tax issues

    Our tax litigation team is one of the largest and longest established in the country. Our expertise covers Indirect Taxes including VAT and Customs, Corporate tax (domestic & international issues), Capital Gains Tax, other Direct Taxes and public law. The team is made up of very experienced litigators (both barristers and solicitors), ex HMRC solicitors and officers and CEDR accredited mediators.

    Our tax litigation lawyers work seamlessly with KPMG’s strong and established tax practice to deliver multidisciplinary advice to best cater to your needs. This allows KPMG’s multidisciplinary team to provide long term strategic and practical advice both before and after a dispute.

    Reduce the risk – take control – resolve contentious tax matters

    Tax litigation and the resolution of disputes can prove costly, disruptive and take up significant resources at the most senior levels. They can last several years: issues that don’t start out as contentious may develop over time.

    What’s more, dealing with them could have wider implications: your response might affect tax positions elsewhere in the business, and in other jurisdictions.

    Contentious tax matters: how we can help

    Responding to contentious tax matters demands specialist legal advice and support. This helps taxpayers take control of their tax disputes. Our specialist team will handle enquiries, dispute resolution or tax litigation, across all taxes.

    Our experienced team will take you through the complete tax compliance cycle. We’ll work with you and your tax team to protect against tax controversies; manage any enquiries and disputes that arise; and resolve them as successfully as possible.

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    Protect

    Reduce the risk of tax controversies by:

    1. considering how to deal with informal requests for information from tax authorities
    2. securing the right risk rating for your business
    3. making voluntary disclosures
    4. providing legal advice on your tax positions.
                                                                                                                                
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    Manage

    Take control of tax enquiries and disputes by:

    1. responding effectively to information requests
    2. identifying, organising and presenting evidence and arguments to support your tax positions
    3. appealing against excessive assessments and assertions of careless or deliberate behaviour
    4. providing you with a detailed strategy for resolving your dispute
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    Resolve

    Maximise your chances of a successful outcome by:

    1. obtaining closure notices promptly once enquiries are completed
    2. securing agreement-to-settlement proposals in line with local tax authorities’ procedures
    3. engaging in alternative dispute resolution processes  
    4. litigating where necessary  
       
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    Our tax disputes insights

    Get ready to deal with your next tax dispute

    How you, as General Counsel or tax leaders, can get ahead of the curve and make sure you’re ready to deal with your next tax dispute.

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    Corporate tax enquiries

    Helping you reach resolutions quickly and efficiently.

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    Recent key cases:

    Fowler v Revenue and Customs Commissioners [2020] UKSC 22 - Deeming provisions; Double taxation treaties; Statutory interpretation

    Revenue and Customs Commissioners v Taylor Clark Leisure Plc [2018] UKSC 35 (also acted in UT and FTT) - Repayments; Time limits; VAT groups

    Volkswagen Financial Services (UK) Ltd v Revenue and Customs Commissioners [2017] UKSC 26 (also acted in Court of Appeal (Civil Division), UT and FTT) - Deductions; EU law; Exempt supplies; Partial exemption; Taxable supplies

    Pendragon Plc v Revenue and Customs Commissioners [2015] UKSC 37 (also acted in Court of Appeal (Civil Division), UT and FTT) - VAT

    Revenue and Customs Commissioners v GMAC UK Plc (C-589/12) EU:C:2014:2131, [2014] S.T.C. 2603 (also acted in UT) - Bad debt relief; Supply of goods; VAT

    Grattan Plc v Revenue and Customs Commissioners (C-310/11) EU:C:2012:822, [2013] S.T.C. 502 (also acted in UT and FTT) - Agents' fees; Assessment; Commission; Directives; Liability to tax; Repayments; Supply of goods

    Dollond & Aitchison Ltd v Customs and Excise Commissioners [2006] E.C.R. I-2129 (also acted in VAT and Duties Tribunal (Manchester)) - Customs value; EC law; Supply of services

    Delinian Ltd (formerly Euromoney Institutional Investor Plc) v Revenue and Customs Commissioners [2023] EWCA Civ 1281 (also acted in UT and FTT) - Capital gains tax; Corporation tax; Exchange; Shares

    Archer v Revenue and Customs Commissioners [2023] EWCA Civ 626 (also acted in UT and FTT) - Accelerated payment notices; Appeals; Closure notices; Judicial review

    Altrad Services Ltd (formerly Cape Industrial Services Ltd) v Revenue and Customs Commissioners [2023] EWCA Civ 474 (also acted in UT and FTT)  - Capital allowances; Grounds for appeal; Plant and machinery allowances

    Revenue and Customs Commissioners v Devon Waste Management Ltd, Revenue and Customs Commissioners v Biffa Waste Services Ltd, Devon Waste Management Ltd v Revenue and Customs Commissioners, Biffa Waste Services Ltd v Revenue and Customs Commissioners [2021] EWCA Civ 584 (KPMG acted for Devon Waste Management Ltd, whilst EY represented the other respondents. KPMG also acted in FTT) - Disposals; Landfill tax; Statutory interpretation;

    R. (on the application of Archer) v Revenue and Customs Commissioners [2019] EWCA Civ 1021 (also acted in Queen’s Bench Division (Administrative Court)) - Accelerated payment notices; Judicial review

    Revenue and Customs Commissioners v Fortyseven Park Street Ltd [2019] EWCA Civ 849 (also acted in UT and FTT) - Exempt supplies; Hotels; VAT

    Farnborough Airport Properties Co v Revenue and Customs Commissioners [2019] EWCA Civ 118 (also acted in UT and FTT) - Corporation tax; Groups of companies; Receivers' powers and duties; Receivership; Statutory interpretation

    R. (on the application of Archer) v Revenue and Customs Commissioners [2017] EWCA Civ 1962 (also acted in the Queen's Bench Division (Administrative Court)) - Amendments; Closure notices; Income tax; Mistake; Self-assessment

    Associated Newspapers Ltd v Revenue and Customs Commissioners [2017] EWCA Civ 54 (also acted in UT and FTT) - Consideration; Fiscal neutrality; Newspapers; VAT

    Patersons of Greenoakhill Ltd v Revenue and Customs Commissioners [2016] EWCA Civ 1250 (also acted in UT and FTT) - Biodegradable waste; Electricity generation; Landfill tax

    United Grand Lodge of England v Revenue and Customs Commissioners [2016] EWCA Civ 1239 (also acted in UT and FTT) - Exemptions; VAT

    Revenue and Customs Commissioners v GMAC UK Plc, British Telecommunications Plc v Revenue and Customs Commissioners [2016] EWCA Civ 1015 (also acted in UT and FTT) - Bad debt relief; EU law; Supply of goods; Time limits; VAT

    University of Huddersfield Higher Education Corp v Revenue and Customs Commissioners [2016] EWCA Civ 440 (also acted in UT and FTT) - Discretionary trusts; Lease and leaseback; VAT

    Hargreaves v Revenue and Customs Commissioners [2016] EWCA Civ 174 (also acted in UT) - Burden of proof; Discovery assessments; Income tax; Preliminary hearings; Residence; Self-assessment


    Revenue and Customs Commissioners v Open University     [2016] EWCA Civ 114 (also acted in UT and FTT) - Educational activities; Exempt supplies; Public authorities; VAT

    Boots Co Plc v Revenue and Customs Commissioners [2009] EWCA Civ 1396 (also acted in High Court (Chancery Division) and VAT and Duties Tribunal (London)) - Agreements; Interpretation; Output tax; Overpayments; Repayments

    Midlands Co-operative Society Ltd v Revenue and Customs Commissioners [2008] EWCA Civ 305 (also acted in High Court (Chancery Division) and VAT and Duties Tribunal) - Assignment; Repayments; Statutory rights

    United Grand Lodge of England v Revenue and Customs Commissioners [2023] UKUT 307 (TCC) (also acted in FTT) - Exemptions; Membership fees; Subscriptions; Supply of services

    R. (on the application of Glint Pay Services Ltd) v Revenue and Customs Commissioners [2023] EWHC 1621 (Admin) - Exempt supplies; Gold; Input tax; Legitimate expectation; Zero rating


    R. (on the application of Gloucestershire Hospitals NHS Foundation Trust) v Revenue and Customs Commissioners [2023] UKUT 28 (TCC) - Consumable goods; Contracting out; Input tax; Medical supplies; Single supplies; Supply of services; Tax refunds

    HBOS Plc v Revenue and Customs Commissioners [2023] UKUT 13 (TCC) (also acted in UT in 2022 and FTT) - Bad debt relief; Interest; Tax refunds

    Revenue and Customs Commissioners v Chelmsford City Council [2022] UKUT 149 (TCC) (also acted in FTT) - Economic activities; Local authorities; Taxable persons; Taxable supplies

    HSBC Electronic Data Processing (Guangdong) Ltd v Revenue and Customs Commissioners [2022] UKUT 41 (TCC) (also acted in FTT) - Fixed establishment; VAT groups

    Hargreaves v Revenue and Customs Commissioners [2022] UKUT 34 (TCC) -  Discovery assessments; Income tax

    Volkswagen Financial Services (UK) Ltd v Revenue and Customs Commissioners [2020] UKUT 42 (TCC) (also acted in FTT) - Margin schemes; Output tax; Supply of goods; Tax refunds

    Beagles v Revenue and Customs Commissioners [2018] UKUT 380 (TCC) (also acted in FTT) -  Discovery assessments; Income tax; Time limits

    Revenue and Customs Commissioners v Stoke by Nayland Golf and Leisure Ltd [2018] UKUT 308 (TCC) (also acted in FTT) - Arm's length transactions; Distribution; Exempt supplies; VAT

    PJ Thory Ltd v Revenue and Customs Commissioners [2018] UKUT 187 (TCC) (also acted in FTT) - Aggregates levy; Exemptions

    Marriott Rewards LLC v Revenue and Customs Commissioners [2018] UKUT 129 (TCC) – (acted for the second appellant only, Whitbread Plc) also acted in FTT) - Liability to tax; Supply of services; VAT

    Revenue and Customs Commissioners v Imperial College of Science, Technology and Medicine [2016] UKUT 278 (TCC) (also acted in FTT) - Apportionment; Exempt supplies; Input tax; Overheads; Partial exemption; Tax refunds; Taxable supplies; Universities; VAT

    E Buyer UK Ltd v Revenue and Customs Commissioners, Revenue and Customs Commissioners v Citibank NA [2016] UKUT 123 (TCC) (KPMG acted for E-Buyer only in this case) - Disclosure; VAT

    Revenue and Customs Commissioners v General Motors (UK) Ltd [2015] UKUT 605 (TCC) (also acted in FTT) - Cars; Overpayments; Producers; Repayments; Self-supply; VAT

    Why Pay More For Cars Ltd v Revenue and Customs Commissioners [2015] UKUT 468 (TCC) (also acted in FTT) - Bonus payments; Repayments; VAT; Vehicles

    N & M Walkingshaw Ltd v Revenue and Customs Commissioners [2015] UKUT 123 (TCC) (also acted in FTT) - Cars; Consideration; Discounts; Part exchange; Supply of goods; VAT

    R. (on the application of GSTS Pathology LLP) v Revenue and Customs Commissioners [2013] EWHC 1801 (Admin) - Advance rulings; Exempt supplies; Interim injunctions; Legitimate expectation; Supply of services

    Bridport and West Dorset Golf Club Ltd v Revenue and Customs Commissioners [2012] UKUT 272 (TCC) (also acted in FTT) - Clubs; Exempt supplies; Golf

    GlaxoSmithKline Services Unltd v Revenue and Customs Commissioners [2011] UKUT 432 (TCC) - Beverages; Consumers; Food products; Sportspersons; Zero rating

    Klincke v Revenue and Customs Commissioners [2010] UKUT 230 (TCC) (also acted in FTT) - Capital gains; Foreign currencies; Loan notes; Qualifying corporate bonds; Redemption

    Revenue and Customs Commissioners v Grattan Plc [2009] EWHC 364 (Ch) - Notices of hearing; Striking out; VAT and duties tribunals

    Leisure Pass Group Ltd v Revenue and Customs Commissioners [2008] EWHC 2158 (Ch) (also acted in VAT and Duties Tribunal) - Supply of services; Vouchers

    Riverside Housing Association Ltd v Revenue and Customs Commissioners     [2006] EWHC 2383 (Ch) (also acted in VAT and Duties Tribunal (Manchester) - Buildings; Business purpose; Housing associations; Zero rating

    MBNA Europe Bank Ltd v Revenue and Customs Commissioners [2006] EWHC 2326 (Ch) - Consideration; Credit cards; Input tax; Output tax; Partial exemption; Securitisation; Supplies

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