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Dispute Resolution

Resolve tax issues, and help prevent them arising

Many actual or potential tax problems ultimately turn on the strength of the real time evidence: recording what you are doing, where in the world you are doing it, and why you are doing it in the first place. Other problems will turn on whether the formal assessments have been raised or claims have been made on time, on whether the tax authority has the legal power to call for documents, or whether the tax authority has acted lawfully and reasonably in making a particular decision. It is much more than doing technical analysis and presenting tax technical arguments.

Whilst every problem is different, each one needs a realistic and an unvarnished analysis of the relative strengths and weaknesses, a clear strategy that provides the framework to solving the problem and a comprehensive plan that guides the taxpayer through the steps to resolution.

PwC’s multi-disciplinary team of tax and commercial litigation lawyers, tax advisers and senior ex-tax authority officials is uniquely positioned to give you clear, straight-talking and robust legal and tax advice to help you achieve the best possible outcome - including helping you prevent the problem happening in the first place.

Understanding how tax authorities and the courts tend to approach particular tax problems, and being realistic about the relative strengths and weaknesses of any particular issue for both the taxpayer and the tax authority, means the merits of your case get the best chance of success. It also means you get the best possible legal and tax advice and support to help you avoid the tax problem arising in the first place.

This is as important when you are applying for a tax clearance, responding to tax authority correspondence or negotiating with a tax authority, as when you are going through alternative dispute resolution or heading towards litigation. The ability to communicate effectively with revenue authorities and other decision-makers is critical - and this means understanding their perspective.

We have the capabilities and credentials you need

We are uniquely positioned to help you both solve existing tax problems and help prevent new ones arising. We have a multidisciplinary, worldwide, team of practising solicitors and barristers, tax advisers, accountants, economists and experts in risk and technology, fully integrated with our long-established team of ex-tax authority senior officials.

In the UK, we have over 90 people focussed on providing contentious tax advice, negotiating with tax authorities, and leading alternative dispute resolution and litigation. This includes 26 partners and directors, and 15 experienced commercial and regulatory litigators adding to our capabilities and experience. Globally, we have over 500 PwC professionals focussed on contentious tax advice, tax negotiations and settlements, and dispute resolution including litigation. Many more of our client cases settle on positive terms (including through mediation and other alternative dispute resolution) than go to litigation, but we represent clients from the First-tier Tribunal to the Supreme Court, the Commercial Court, the Administrative Court. We cover all taxes (direct, indirect, personal, environmental, excise, duties and customs).

Our legal advice to you (on tax and wider legal issues) can be given under legal professional privilege.

We are particularly noted for our expertise in international and multi-jurisdictional matters, which is enhanced by knowledge sharing and collaboration across PwC’s global legal network, the largest of its kind.

Vast commercial disputes expertise

As well as working on our complex tax cases, our Commercial Disputes team are able to help you with everything from contractual disputes, professional negligence claims, investor/shareholder disputes, partnership disputes to civil fraud claims which frequently involve risk and reputation management concerns.

We regularly carry out complex and multi-jurisdictional internal investigations into a wide variety of tax, commercial and regulatory matters, working closely with colleagues around the world. This includes potential financial crime and money laundering matters. We are particularly experienced in investigating internal policy breaches, with a focus on helping to protect your company’s reputation at a time of increased scrutiny from regulators, both domestic and global.

Forensics and corporate intelligence capabilities

We also regularly work alongside the firm’s forensic and corporate intelligence teams to provide a bespoke asset tracing offering that harnesses the power of PwC services to its full effect to deliver a complete one stop shop service for clients in multi-jurisdictional enforcement battles. We appear in courts, tribunals and international arbitration fora across the world on behalf of a diverse range of clients and a vast array of industrial and professional sectors.

Local, regional and international regulatory disputes expertise

In the last 12 months, we have advised a number of clients on international trade sanctions, including liaising with regulators on their behalf, making voluntary disclosures in relation to breaches, and securing release of funds frozen in overseas jurisdictions in which sanctions have been imposed. We have also undertaken large scale international investigations for clients in suspected cases of fraud and corruption, including cases of suspected insider dealing.

Our Regulatory Disputes team are focussed on helping you to ensure that your business operates in compliance within the UK, regional and international regulatory frameworks, including the UK Bribery Act, UK Modern Slavery Act, the corporate criminal offences under the UK Criminal Finances Act and the Foreign Corrupt Practices Act. We are particularly experienced in investigating internal policy breaches, with a focus on helping to protect your company’s reputation at a time of increased scrutiny from regulators, both domestic and global.

Find out more about our capabilities and credentials and recent tax, commercial and regulatory disputes expertise.

Our capabilities

Our range of experience is extensive and includes:

  • Boardroom / shareholder disputes;
  • Corporate disputes;
  • Contractual and supply chain disputes;
  • Debt recovery;
  • Enforcement of foreign awards and judgments;
  • Financial services disputes;
  • Fraud (including asset tracing and injunctive relief);
  • Intellectual property disputes;
  • IT outsourcing disputes;
  • Joint venture and partnership disputes;
  • Judicial Review;
  • Professional negligence;
  • Reputation management (including defamation, misuse of confidential information and anti-counterfeiting actions);
  • Rectification, mistake and Hastings Bass applications;
  • Trust claims arising from breach of trust and advising Trustees and Beneficiaries on their obligations/remedies.
  • Enquiry management;
  • HMRC Administrative Powers;
  • Forensic review;
  • Escalation / ADR;
  • Management of HMRC Governance Boards;
  • Litigation and settlement strategy;
  • Cross border disputes;
  • Competent Authority Provisions / Mutual Agreement Procedure;
  • Crown preference - legal and solvency implications;

Recent Commercial Disputes

  • We represented a client in a contested proof of debt claim in the context of a Members Voluntary Liquidation before the High Court (Companies Court) which led to a comprehensive settlement and significant payment to the client.
  • We managed a cross-border dispute involving asset tracing for a financial services client and advised on recovery proceedings in multiple jurisdictions which led to a successful compromise and recovery.
  • We advised on a professional negligence claim against a leading law firm after mistakes in a Pension Deed had been discovered.
  • We managed a cross-border Trust/Pension dispute involving breach of fiduciary duty by scheme trustees and which included Hastings Bass proceedings offshore which led to working with local lawyers to successfully obtain a Hastings Bass Order.
  • We successfully advised partners on winding up and retiring from an LLP after a 10 year dispute by negotiated settlement at a mediation.

Recent Regulatory Disputes projects

  • We led a compliance and culture review for a FTSE 100 tourism operator, focusing on third party contracting and tax. The review involved conducting over 40 interviews with senior stakeholders and advising on remediation.
  • We managed a multi-jurisdictional customs duty fraud investigation for a UK plc, including disclosures to competent regulatory authorities in the UK and the Middle East.
  • We advised a FTSE250 chemicals company in relation to a multi-jurisdictional customs duty and import tax fraud investigation.
  • We advised a NYSE listed, commercial real estate service provider in relation to an investigation into fraudulent employee activity in Germany and a wider financial crime compliance review in the EMEA region.

Recent Tax Disputes projects

  • We are acting in a Judicial Review claim in the Administrative Court for a major multinational involving a purported revocation of an HMRC clearance.
  • We are conducting litigation in the High Court involving alleged fraudulent misrepresentation in one of the UK’s largest current tax cases
  • We are representing 20 companies in High Court Group Litigation involving compliance with EU law
  • We are representing a business involved in a transfer pricing dispute, involving appeals to the First Tier Tax Tribunal and potential alternative dispute resolution
  • We represented 25 businesses in relation to the decision of the EC Commission that the UK’s controlled foreign companies regime gave rise to unlawful state aid (including filing 20 annulment applications at the European Court.

Contact us

Mark Whitehouse

Mark Whitehouse

Legal partner - all taxes, PwC United Kingdom

Tel: +44 (0)7715 705102

Agnes Quashie

Agnes Quashie

Partner, PwC United Kingdom

Tel: +44 (0)7764 235494

Stephen Morse

Stephen Morse

Partner, PwC United Kingdom

Tel: +44 (0)7590 351937

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