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Deloitte Tax Controversy

Current trends suggest that multinational organisations and individuals will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on implementation. Deloitte's tax dispute resolution teams include former tax authority officials, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses at all phases of the tax dispute resolution cycle.

Deloitte’s tax controversy team supports a full spectrum of clients ranging from multinational corporations to individuals on a range of contentious tax matters.

The team brings together leading practitioners from Deloitte’s tax advisory, legal and risk advisory teams.

With a team that is made up of tax specialists, accountants, solicitors, economists, former HMRC inspectors, data analysts and information technology experts, we achieve successful outcomes through risk management consulting, negotiation, alternative dispute resolution, and litigation.

We advise on domestic and international matters, and have active engagements in the following areas:

  • Settlement of tax disputes as part of HMRC’s High Risk Corporates Programme and the Profit Diversion Compliance Facility
  • Collaborative dispute resolution on numerous enquiries, including Transfer Pricing and Diverted Profits Tax; Expenses of Management; Residence, Permanent Establishments and Controlled Foreign Companies;
  • Avoiding transfer pricing controversy through Advanced Pricing Agreements and resolving transfer pricing controversy through Mutual Agreement Procedures.
  • Complex personal tax enquiries including domicile positions and trust status
  • Investigations under Code of Practice 8 and 9
  • Voluntary disclosures to HMRC 
  • State Aid challenges
  • Technology enabled handling of HMRC document and information requests
  • Negotiations and appeals on discovery assessments, penalties and closure notices
  • Alternative Dispute Resolution in relation to direct and indirect tax matters 
  • Litigation (from First-tier Tribunal to the Supreme Court)

Spotlight

Alternative Dispute Resolution

Alternative Dispute Resolution is a flexible process which has been introduced by HMRC in an attempt to resolve tax disputes more effectively. Mediation, which is also commonly referred to as ‘facilitation’ by HMRC, falls under the Alternative Dispute Resolution umbrella and has become increasingly popular and successful as a cost effective, consensual and efficient means of resolving tax disputes.

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Tax disclosure and transparency

The last decade has seen significant tax and regulatory change, including the introduction of global information exchange programmes like the Common Reporting Standard, new and increased penalty regimes for offshore tax compliance errors, proposals to extend HMRC’s powers to assess tax and issue formal information notices, the introduction of the Criminal Finances Act and the ongoing complexity and development of the UK tax system. At the same time, a decrease in HMRC staff numbers has seen HMRC develop a new, data-analytics focused approach to tax enquiries.

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Direct Tax Dispute Resolution and Litigation

Whether your business is currently in a dispute with HM Revenue & Customs or is anticipating a dispute, there are a number of ways in which we can help. Litigation can be an effective means of resolving disputes where both parties have reached an impasse.

However, increasingly Alternative Dispute Resolution is being used successfully by taxpayers and HMRC to resolve complex and long-running disputes. Deloitte can draw on many years of experience to assist you with either approach.

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Key contacts

Matt Batham

Matt Batham

Partner

Matt is a Chartered Accountant who leads the Consumer Business Tax practice. He has 19 years’ experience in tax and focuses on US multinationals, particularly the hotel sector. Matt’s experience inclu... More

Glen Harling

Glen Harling

Partner

Glen specialises in handling and advising on all types of disputes with the UK tax authority. Glen is a qualified solicitor and CEDR accredited mediator. He has a large litigation portfolio and advise... More

Key contacts

David Hume

David Hume

Vice Chairman and Partner

David is a Vice Chairman of our firm and a senior corporate tax partner based in our London office. As well as being the Lead Tax Partner on a number of our largest clients David leads the tax offerin... More

Eddie Morris

Eddie Morris

Partner

Eddie has 20 years transfer pricing and international tax experience, 8 of those years are with Deloitte and 12 of those years he worked at HMRC International Division. He now represents Deloitte at H... More