We are instructed in complex tax disputes, particularly those with a proceeds of crime dimension or where civil and criminal proceedings run in parallel. We advise on strategy across all proceedings — including whether to seek a stay, negotiation with counterparties, and engagement with investigators.

Our work in this area includes challenging the exercise of HMRC functions and powers, such as warrant searches, account freezing orders, Schedule 36 information notices, penalties, and accelerated payment notices. We advise on the corporate offence of failure to prevent the facilitation of tax evasion under the Criminal Finances Act 2017, including the development of reasonable prevention procedures, self-reporting, and responding to investigations.

Members regularly advise on criminal tax investigations, including communication and negotiation with investigators, interview strategy, and the risk of restraint and account freezing. We also act on tax irregularities raised by clients or whistleblowers, advising on strategic responses to avoid criminal outcomes and mitigate penalties, and on HMRC inquiries where there is a risk of referral to the First-tier or Upper Tribunal.

We advise on internal tax investigations, including questions of procedure, disclosure, and privilege. Our members appear in tax appeals and judicial review proceedings before the First-tier Tribunal, Upper Tribunal, Crown Court, High Court, and Court of Appeal.

Representative cases

Close cases

£30m plus tax case relating to the burden of proof in penalty cases

Advising a company on challenging HMRC’s decision to cancel its registration under the UK anti-money laundering regime, in a matter involving allegations of CJRS (furlough) fraud and PAYE irregularities

Advising company director in connection with HMRC investigation into employee benefit trust tax avoidance scheme

Defending a solicitor, facing counts spanning conspiracy to defraud, fraudulent trading, failure to keep accounting records, and conspiracy to cheat the revenue

Successfully appealing against closure notices based upon valuations of companies.

Defending a company director alleged to be part of a Conspiracy to Defraud HMRC of £8m by encouraging investors to liberate their pensions early without paying the tax due

Acquittal after decade of proceedings: Conspiracy to defraud HMRC in pension fraud

Presenting professional discipline proceedings for Taxation Disciplinary Board

R (On Application of AFC, AA) v C Magistrates’ Court ex parte Her Majesty's Revenue and Customs

Judicial Review of HM Revenue and Customs’ investigatory conduct relating to film scheme tax relief and input tax recovery.

HMRC v Windsor & Others.

Lead defendant in a 6 month trial relating to duty and VAT fraud, including issues of abuse of process, disclosure and intrusive surveillance.

Nuttall & Others v HMRC.

Representing lead appellant in Tax Tribunal dispute re: company valuations for gift aid.

Field Opportunities v HMRC.

VAT input case involving Kittel principles. Alistair was described, in the FTT’s decision, as having “acute forensic skills.”

EAH Ltd. v HMRC

First-tier tax tribunal appeal of a decision to deny VAT recovery involving UK supplied helicopters held under US owner-operated trusts.

Secured a settlement with HMRC regarding the valuation of a property in a tax dispute for a high-net-worth client based in Kuwait. Praised by the client for being “pro-active, prompt, honest, pragmatic”.

Advised a company on challenging HMRC’s decision to cancel its registration under the UK anti-money laundering regime, in a matter involving allegations of CJRS (furlough) fraud and PAYE irregularities.

Assisted King’s Counsel in advising on an investigation into the corporate offence of the failure to prevent the facilitation of tax evasion.

Challenge to legality of HMRC action in relation to WOWGR approvals

Representing a Defendant in respect of a multi-party claim for unlawful means conspiracy, deceit, knowing receipt and dishonest assistance, freezing orders and proprietary injunctions brought by HMRC

Defending IFA charged with alleged pension scheme tax fraud

Defending a solicitor charged with conspiracy to defraud and money laundering arising out of investment trusts

Leading counsel in the restraint proceedings arising from a criminal prosecution into alleged VAT fraud, cheating the public revenue, fraud by false representation and money laundering

Representing client in VAT input case involving Kittel principles

Instructed to represent a company director in prosecution for corporation tax group relief fraud

Judicial Review of HM Revenue and Customs’ investigatory conduct relating to film scheme tax relief and input tax recovery

Malde & Others v HMRC.

Successfully represented the Appellants in 3 month appeal against personal liability notices and penalties relating to alleged huge diversion and VAT fraud. The case involved multi-jurisdictions and companies and trusts from numerous countries.

Mcarthur and others.

Successful appeal against disallowal of claims in relation to charitable tax relief.

Seabrook Warehouses v HMRC.

Successful challenge to withdrawal of approvals for operations relating to Bonded warehouses, including litigation in the Administrative Court, Court of Appeal and the First Tier Tax Tribunal.

Operation Amazon

The most complex tax case HMRC have ever prosecuted. For the first defendant.

Currently instructed in relation to a customs duty and import VAT dispute with HMRC.

As part of a team, assisted with corporate internal tax investigations and related extensive disclosure exercises. Heavily involved in drafting related advice on protecting legal professional privilege in such circumstances.

Involved in multiple tax judicial reviews, including in case strategy and procedure prior to proceedings before the Administrative Court, and an application for permission to appeal to the Supreme Court.

HMRC v X

Strategic and day-to-day involvement in a major tax appeal for a Fortune 500 company before the First-tier Tribunal and then Upper Tribunal, spanning 3 years.