Tax Dispute Resolution

Tax Dispute Resolution

We help clients to resolve tax disputes and achieve certainty. If your business has open tax enquiries or you are concerned about particular tax issues, KPMG's Tax Dispute Resolution team can help you achieve resolution quickly and effectively.

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Disputes can arise across all taxes and occur for a variety of reasons. KPMG’s Tax Dispute Resolution team can help through all stages of the dispute process, including:


Dispute prevention – assistance in transaction implementation and documentation, preparation of tax return filing positions and disclosure, applications for formal clearances or early informal agreement through real time working with HMRC.

Dispute management – assistance in engaging effectively with HMRC to progress issues efficiently to reduce or mitigate disruption to your business. We can assist you at all stages of an enquiry process from risk assessment to tax enquiry resolution.

Dispute resolution – assistance with complex disputes. We can assist you to develop your strategies, align your business objectives and enable you to evaluate potential settlement outcomes whether through agreement or litigation and assist with working with HMRC to reach resolution.


Resolving disputes with HMRC can be complicated – knowing the people and the process can make a difference. To achieve your desired outcome you can benefit from assistance by people who are experts in this field with decades of experience in dealing with tax enquiries.


What's on your Mind?

Does your business have ongoing tax enquiries or complex transactions? Would you benefit from professional advice and assistance in progressing to resolution with HMRC? Possible triggers could include:


  • Open tax position(s) resulting in tax reporting issues, large provisions, uncertainty on availability of losses, cash tax on account with HMRC pending resolution
  • A significant single issue where lack of agreement with HMRC is causing a business issue or delaying/preventing a transaction
  • Limited progress being made with HMRC due to absence of or insufficient resolution strategy
  • HMRC viewing your business as 'high risk' and more likely to raise enquiries
  • Change in the business (merger/acquisition), management team or tax strategy that provides an opportunity for a new relationship with HMRC
  • Transaction being implemented where HMRC could have a different view of the tax analysis
  • HMRC demands for accelerated payment of disputed tax e.g. as a result of a ‘follower notice’
  • HMRC is preparing for litigation


Helping bring you certainty 

We have extensive experience of assisting organisations resolve tax disputes whilst maintaining an effective working relationship with HMRC. As well as resolving significant single issue disputes, our team has a strong understanding, based on practical experience, of how best to approach resolving large, complex, multifaceted tax disputes across all taxes with HMRC. This experience includes working through a large number of significant tax settlements through formal HMRC resolution channels including:


  • High Risk Corporates Programme (HRCP) for organisations dealt with by HMRC Large Business with significant disputes
  • Wealthy & Mid-Size Business Compliance (WMSBC) enquiries covering all business taxes and possible associated enquiries into directors/shareholders
  • Assisting clients prepare settlement proposals for consideration by HMRC’s Tax Disputes Resolution Board (TDRB)
  • Alternative Dispute Resolution (ADR) for disputes capable of resolution using mediation techniques

Through these projects we have helped clients achieve certainty on disputed tax issues quickly and efficiently and in a way which enhanced their relationship with HMRC.


A well–established, tested approach 

Our methodology incorporates a twin-track approach to help organisations progress disputed tax issues towards resolution with HMRC:


  • Our approach aims to help organisations progress difficult disputes collaboratively towards reaching agreement with HMRC. Where appropriate, we will advise that you work to ‘litigation standard’ as this will maximise your chances of settling whilst putting you in control of the process should litigation become necessary
  • Where agreement with HMRC on acceptable terms cannot be achieved, our approach is to manage the litigation process in a non-confrontational way

Through this twin-track approach, we can facilitate resolution of contentious issues whilst enabling organisations to stay in control of the process.


What are the benefits for you?

Potential benefits can include:


  • Certainty of filing positions and/or availability of losses/reliefs 
  • Enhanced relationship and reduced risk profile with HMRC
  • Enhanced reputation with internal and external stakeholders.
  • Release or increased accuracy of tax provisions
  • Overpaid cash tax refunded by HMRC
  • Reduced compliance costs with tax department resources freed up for more valuable work  



Through our experience of recent significant projects we have a track record of resolving tax disputes for clients:


  • Our multi-disciplinary team has industry-leading skills in tax dispute management, which not only deliver clients the right outcome when settling historical issues, but also secure future benefits through our forward looking approach
  • Our collaborative approach facilitates the resolution of contentious issues, whilst enabling clients to stay in control and enhance their reputation with both internal and external stakeholders
  • We have excellent credentials established from decades of experience of HMRC enquiries and tax disputes governance procedures   


Case Study 1

Our client, a household name, became the subject of HMRC’s intensive High-Risk Corporates Programme (HRCP) in 2015. There were four major open issues, with tax at stake totalling between £50m and £100m as well as serious reputational risks from some of HMRC’s contentions. KPMG led the engagement with HMRC, working alongside the client. We agreed a project plan with HMRC, helped the client prepare for senior-level meetings with HMRC and advised on how best to manage operational interactions with HMRC. 

We facilitated the debate with HMRC about the factual and legal analysis. This involved helping the client understand and present its case while identifying and recognising the points that were most important to HMRC. Finally, we helped the client structure a settlement proposal which the Tax Assurance Commissioner approved, a basis of resolving all the open issues that both the client and HMRC regarded as a win/win. The whole resolution process took little more than six months, a far shorter time to wait for certainty than any alternative approach could have achieved. With our help, the client now expects to be designated as ‘low risk’ next year.


Case study 2

A privately owned business received contact from HMRC advising they wanted to undertake a ‘risk assessment’. HMRC visited the company premises and were allowed unfettered access to company records and electronic data which HMRC took away. On interrogation of the company records HMRC asserted significant underpayment of payroll, indirect and corporate taxes and extended enquiries into the personal affairs of the business owner. HMRC raised estimated assessments and requested payment on account of significant amounts of tax.

KPMG were appointed by the business to gain control of the HMRC enquiries. By establishing an agreed action plan we facilitated the building of trust between the business and HMRC and enabled the enquiries to be brought to a prompt and satisfactory conclusion. The tax liabilities were agreed significantly lower than HMRC estimates with potential penalties suspended. By working collaboratively with HMRC we enabled the business to be designated as ‘low risk’ to reduce or mitigate the likelihood of future HMRC enquiries.


Our Experts

Chris Davidson

Tax Director 

T: 020 7694 5752


Amanda Brown

Legal Services Partner

t: 020 7311 4728 


Kevin Elliott

Tax Director

t: 020 7311 2487


Chris has nearly 40 years of experience in tax administration, the majority at HMRC, where Chris held several senior positions including being Head of Anti-Avoidance. Chris has invaluable insight gained through first-hand experience of HMRC’s recently established tax disputes governance procedures. 

Amanda is a Partner in KPMG’s UK Tax Legal Services and has significant experience of litigating tax disputes over a period of nearly 25 years. Amanda has assisted clients through the litigation process to successful outcomes and can also help clients evaluate a litigated outcome as an alternative to negotiated settlement.

Kevin has 30 years of experience working on tax disputes both as a senior tax authority investigator and member of KPMG’s Tax Investigations & Dispute Resolution practice. Kevin has led a large number of significant tax settlement projects and facilitates in ADR cases as a CEDR accredited mediator.

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