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; and
• 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.