Tax Disputes

We are one of the largest dedicated tax disputes teams in the UK. We’ve litigated at every level of UK court or Tax Tribunal and at the CJEU. We also have experience in ADR and mediation. A substantial part of our work is in settling disputes before they are litigated. The team has settled several multi billion pound disputes relating to corporation tax and act for a quarter of the FTSE 100.

Our expertise is in the full range of direct and indirect taxes. We also advise on issues relating to tax risk.

We have significant experience in resolving deadlock in disputes. The team have obtained a number of substantial repayments in relation to SDRT, CFCs and corporation tax deductions for expenses for our clients.

Principal areas of practice include:

  • HRCP settlement negotiations
  • Settlement Agreements
  • Group actions in the Tax Tribunals and High Court
  • Tax planning challenges
  • Discovery and other procedural issues
  • Legal professional privilege
  • Judicial Review
  • Complaints to the European Commission.

The team’s primary areas of tax practice include:

  • CFCs
  • International transfer pricing disputes
  • Employment Taxes
  • Loan Relationships
  • VAT
  • IPT
  • Customs
  • Excise
  • Hydrocarbon oils
  • Environment levies including landfill tax, climate change levy and aggregates levy.

Our experience in active litigation is particularly strong for example we were instructed to act on one of the most widely reported cases in the last 12 months, the Prudential case on legal professional privilege. The team acted before the High Court, Court of Appeal and Supreme Court in the ground breaking case.

The team is also instructed on the ground breaking Investment Trusts Companies case which seeks to establish the ability for customers to make High Court restitutionary claims.

The Team

Our team is headed by Mark Whitehouse. with David Anderson leading the Indirect Tax Litigation team. They are supported by 11 qualified lawyers, including CEDR Accredited Mediators. Lawyers in the team have a range of experience including the European Commission, HMRC Solicitor’s Office, HM Customs and Excise, HM Treasury and the Court of Appeal.

We’re ranked by Legal 500 and Chambers and Partners 2013. Mark Whitehouse is a Band 1 individual and David Anderson and “Up and Coming” individual by Chambers and Partners. Mark Whitehouse and David Anderson were also recognised as Tax Controversy Leaders by International Tax Review in 2013. The team are proud winners of the Taxation "Best Tax Team in a Law Firm" award 2014. 

If you would like more information on how we can help you please contact Mark Whitehouse.

Contact us

Mark Whitehouse

Legal partner - all taxes, PwC United Kingdom

Tel: +44 (0)7715 705102

David Anderson

Indirect Tax partner, PwC United Kingdom

Tel: +44 (0)16 1245 2990

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