UK domestic

Withers’ UK tax investigation team is made up of highly experienced professionals who have spent decades advising on complex and high stakes cases. Our team includes members who have worked within the tax authorities and have valuable insight into their methods and approach to enquiries. What’s more, the team is able to call on skilled colleagues based in the US, Europe and Asia, providing seamless assistance on cross-border cases.

Our tax investigations experience covers both direct and indirect taxes, such as Income Tax, Capital Gains Tax, Inheritance Tax and Corporation Tax; VAT, Stamp Duties and Customs and Excise duties.

We advise on all areas of tax investigations, both domestically and internationally, including:

  • Information exchange / settlement opportunities including Swiss agreements, Liechtenstein Disclosure Facility, Crown Dependencies disclosure facilities, FATCA and UK FATCA
  • Code of Practice 8: Marketed tax avoidance schemes (DOTAS schemes involving high net worth individuals), accelerated payment notices and follower notices
  • Code of Practice 9/contractual disclosure facility including Civil investigation of fraud
  • Criminal investigations, including offences of:
    • Conspiracy/cheating the Public Revenue. Conspiracy to defraud, Fraud Act offences and money laundering. Pension frauds. Construction industry (CIS) frauds. Missing Trader Intra-Community frauds (MTIC). Regulatory offences
    • HMRC investigations often include the use of mutual legal assistance, mutual administrative assistance, bilateral tax treaties, extradition, search warrants, judicial review, injunctions, SOCPA production orders and legal professional privilege issues.

‘They have a fantastic understanding of what they are doing. They are very good at dealing with the client, and immensely professional – very practical and very prompt.’ (Chambers 2014)

‘A very well-respected, high-class operation.’ (Chambers 2014)

‘able to quickly gain a client's complete trust.’ (Chambers 2014)

Recent work

  • Acting for high profile individuals in the international football industry in relation to a Code of Practice 8 investigation.
  • Securing a nil penalty on liabilities arising from taxable remittances following a tax return check under Section 9A Taxes Management Act 1970 for a non-UK domiciled high net worth individual.
  • Advised in respect of a multimillion pound marketed tax avoidance scheme which HMRC suspect is fraudulent.
  • Advised on a £5 million pension fraud involving accountants who were acting as trustees and administrators of Pension schemes which were investigated by HMRC, FSA and the Pension Regulator.
  • Advised a number of HNW individuals who have been the subject of Code of Practice 9 investigations arising out of HMRC’s Montpelier tax investigations.


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