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Preventive and Advisory

Tax disputes have quickly gained importance in recent years due to an increasingly confrontational approach taken by global tax authorities and the potential for tax controversies to cause significant reputational damage.  This trend is itself driven by pressure on public revenues and society's changing attitude to tax avoidance and evasion.  We work with clients to help them design and implement controls and procedures to help limit the scope for future conflict.  We also rely on our close links with tax authorities' policy teams to understand the areas of concern to them and help our clients to pro-actively deal with changes in tax policy and administration.

We regularly assist clients with the following preventive and advisory services:

  • Tax risk strategies for larger corporates
  • Risk assessment and design and implementation of policies and procedures to address the new measures targeting the enablers of tax avoidance and evasion
  • Senior Accounting Officer regime compliance
  • Training of staff and on-going monitoring and audit of tax procedures
  • Tax and duty reclaims
  • Supply chain due diligence work

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Work Highlights

Financial services institution: in relation to its development of policies and procedures to mitigate the risks presented by the UK’s forthcoming new extra territorial corporate criminal offence of failure to prevent the facilitation of tax evasion, which provides a statutory defence of having had reasonable preventive procedures in place.

Work Highlights

Technology company: seeking to review its supply chain due diligence procedures following notification that certain transactions had been linked to VAT fraud in another Member State.

Work Highlights

Online marketplace: in order to analyse the potential liabilities arising from the risk of Excise duty unpaid stock being sold on its site.

Work Highlights

Trust and corporate service provider: to review a sample of its client book to identify potentially undeclared tax liabilities and ascertain whether there was evidence of facilitation of tax evasion by the client's staff.

Work Highlights

Sports event organiser: to challenge the UK treatment of a supply following a CJEU decision which gave rise to a substantial reclaim of overpaid VAT.