Transfer pricing


Direct Tax Dispute Resolution and Litigation

Deloitte’s transfer pricing network helps companies manage risks by aligning transfer pricing solutions and the operation of their transfer pricing policies with their global business operations and objectives, assisting them in meeting compliance requirements including preparation of documentation to support their policies and practices, and resolving disputes efficiently.

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.

Our dispute resolution and litigation team provides support and advice across two areas:

  1. Alternative Dispute Resolution
  2. Litigation

Alternative Dispute Resolution / Intervention

The relationship between the taxpayer and HM Revenue & Customs can be strained by long-standing direct and indirect tax disputes.

Our experienced team of ADR/intervention specialists act as an interface between you and HMRC to assist in resolving these long standing issues. Working closely with you and key HMRC personnel we can facilitate a satisfactory agreement for both your business and HMRC as well as helping to build a solid working relationship going forward.


How we can help

  • Meeting with HMRC at senior levels to identify the issues in dispute and a timetable for resolving them;
  • Working with the client and HMRC to resolve the issues;
  • Assisting with detailed and complex modelling to facilitate negotiation;
  • Helping to agree late paid interest and tax geared penalties;
  • Assisting with the drafting of Settlement Agreements;
  • Providing advice and assistance to ensure a strong ongoing relationship between HMRC and the client.


Where ADR is not appropriate, or does not work, litigation should be considered. Our Direct Tax dispute resolution team has extensive experience in providing specialist litigation advice across many industries. We can represent clients in both the First-tier Tribunal and Upper Tribunal, we can help guide your case through the higher courts and our work is protected by litigation when privilege.

Most of our litigation cases do not end up in court. The Tax Tribunal process and, in particular, the independent review procedure enables us to settle most matters with HMRC without recourse to litigation


How we can help

  • Enquiry advice;
  • Obtaining closure notices;
  • Drafting and submitting appeals;
  • Instructing Counsel;
  • Dealing with the independent review;
  • Dealing with Accelerated Payment notices and Follower notices


During the appeal
  • Working with you to conduct the appeal process;
  • Continued support and advice throughout the appeal process;
  • Representation of clients at the tax tribunal;
  • Cost recovery.
Further appeals
  • Dealing with judicial review matters and cases on appeal to the Court of Appeal, Supreme Court and the Court of Justice of the European Union.