Contentious disputed matters

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 ��㣨Leyu��’s strong and established tax practice to deliver multidisciplinary advice to best cater to your needs. This allows ��㣨Leyu��’s multidisciplinary team to provide long term strategic and practical advice both before and after a dispute.

Angela Savin

Partner, ��㣨Leyu�� Law

��㣨Leyu�� in the UK

mail
call

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.

security

Protect

Reduce the risk of tax controversies by:

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

manage_accounts

Manage

Take control of tax enquiries and disputes by:

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

model_training

Resolve

Maximise your chances of a successful outcome by:

obtaining closure notices promptly once enquiries are completed
securing agreement-to-settlement proposals in line with local tax authorities�� procedures
engaging in alternative dispute resolution processes ��
litigating where necessary��
��

Our legal insights

Recent key cases:

��[2020] UKSC 22 - Deeming provisions; Double taxation treaties; Statutory interpretation

��[2018] UKSC 35 (also acted in��and��) - Repayments; Time limits; VAT groups

��[2017] UKSC 26 (also acted in��(Civil Division),��and��) - Deductions; EU law; Exempt supplies; Partial exemption; Taxable supplies

��[2015] UKSC 37 (also acted in��(Civil Division),��and��) - VAT

��EU:C:2014:2131, [2014] S.T.C. 2603 (also acted in��) - Bad debt relief; Supply of goods; VAT

��EU:C:2012:822, [2013] S.T.C. 502 (also acted in��and��) - Agents' fees; Assessment; Commission; Directives; Liability to tax; Repayments; Supply of goods

��[2006] E.C.R. I-2129 (also acted in VAT and Duties Tribunal (Manchester)) - Customs value; EC law; Supply of services

��[2023] EWCA Civ 1281 (also acted in��and��) - Capital gains tax; Corporation tax; Exchange; Shares

��[2023] EWCA Civ 626 (also acted in��and��) - Accelerated payment notices; Appeals; Closure notices; Judicial review

��[2023] EWCA Civ 474 (also acted in��and��) ��- Capital allowances; Grounds for appeal; Plant and machinery allowances

��[2021] EWCA Civ 584 (��㣨Leyu�� acted for Devon Waste Management Ltd, whilst EY represented the other respondents. ��㣨Leyu�� also acted in FTT) - Disposals; Landfill tax; Statutory interpretation;

��[2019] EWCA Civ 1021 (also acted in��(Administrative Court)) - Accelerated payment notices; Judicial review

��[2019] EWCA Civ 849 (also acted in��and��) - Exempt supplies; Hotels; VAT

��[2019] EWCA Civ 118 (also acted in��and��) - Corporation tax; Groups of companies; Receivers' powers and duties; Receivership; Statutory interpretation

��[2017] EWCA Civ 1962 (also acted in the��(Administrative Court)) - Amendments; Closure notices; Income tax; Mistake; Self-assessment

��[2017] EWCA Civ 54 (also acted in��and��) - Consideration; Fiscal neutrality; Newspapers; VAT

��[2016] EWCA Civ 1250 (also acted in��and��) - Biodegradable waste; Electricity generation; Landfill tax

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

��[2016] EWCA Civ 1015 (also acted in��and��) - Bad debt relief; EU law; Supply of goods; Time limits; VAT

��[2016] EWCA Civ 440 (also acted in��and��) - Discretionary trusts; Lease and leaseback; VAT

��[2016] EWCA Civ 174 (also acted in��) - Burden of proof; Discovery assessments; Income tax; Preliminary hearings; Residence; Self-assessment

��[2016] EWCA Civ 114 (also acted in��and��) - Educational activities; Exempt supplies; Public authorities; VAT

��[2009] EWCA Civ 1396 (also acted in��(Chancery Division) and��(London)) - Agreements; Interpretation; Output tax; Overpayments; Repayments

��[2008] EWCA Civ 305 (also acted in��(Chancery Division) and��) - Assignment; Repayments; Statutory rights

��[2023] UKUT 307 (TCC) (also acted in��) - Exemptions; Membership fees; Subscriptions; Supply of services

��[2023] EWHC 1621 (Admin) - Exempt supplies; Gold; Input tax; Legitimate expectation; Zero rating

��[2023] UKUT 28 (TCC) - Consumable goods; Contracting out; Input tax; Medical supplies; Single supplies; Supply of services; Tax refunds

��[2023] UKUT 13 (TCC) (also acted in��in 2022 and��) - Bad debt relief; Interest; Tax refunds

��[2022] UKUT 149 (TCC) (also acted in��) - Economic activities; Local authorities; Taxable persons; Taxable supplies

��[2022] UKUT 41 (TCC) (also acted in��) - Fixed establishment; VAT groups

��[2022] UKUT 34 (TCC) - ��Discovery assessments; Income tax

��[2020] UKUT 42 (TCC) (also acted in��) - Margin schemes; Output tax; Supply of goods; Tax refunds

��[2018] UKUT 380 (TCC) (also acted in��) - ��Discovery assessments; Income tax; Time limits

��[2018] UKUT 308 (TCC) (also acted in��) - Arm's length transactions; Distribution; Exempt supplies; VAT

��[2018] UKUT 187 (TCC) (also acted in��) - Aggregates levy; Exemptions

��[2018] UKUT 129 (TCC) �� (acted for the second appellant only, Whitbread Plc) also acted in��) - Liability to tax; Supply of services; VAT

��[2016] UKUT 278 (TCC) (also acted in��) - Apportionment; Exempt supplies; Input tax; Overheads; Partial exemption; Tax refunds; Taxable supplies; Universities; VAT

��[2016] UKUT 123 (TCC) (��㣨Leyu�� acted for E-Buyer only in this case) - Disclosure; VAT

��[2015] UKUT 605 (TCC) (also acted in��) - Cars; Overpayments; Producers; Repayments; Self-supply; VAT

��[2015] UKUT 468 (TCC) (also acted in��) - Bonus payments; Repayments; VAT; Vehicles

��[2015] UKUT 123 (TCC) (also acted in��) - Cars; Consideration; Discounts; Part exchange; Supply of goods; VAT

��[2013] EWHC 1801 (Admin) - Advance rulings; Exempt supplies; Interim injunctions; Legitimate expectation; Supply of services

��[2012] UKUT 272 (TCC) (also acted in��) - Clubs; Exempt supplies; Golf

��[2011] UKUT 432 (TCC) - Beverages; Consumers; Food products; Sportspersons; Zero rating

��[2010] UKUT 230 (TCC) (also acted in��) - Capital gains; Foreign currencies; Loan notes; Qualifying corporate bonds; Redemption

��[2009] EWHC 364 (Ch) - Notices of hearing; Striking out; VAT and duties tribunals

��[2008] EWHC 2158 (Ch) (also acted in��) - Supply of services; Vouchers
��[2006] EWHC 2383 (Ch) (also acted in��(Manchester) - Buildings; Business purpose; Housing associations; Zero rating

��[2006] EWHC 2326 (Ch) - Consideration; Credit cards; Input tax; Output tax; Partial exemption; Securitisation; Supplies