United Kingdom


  • Service: Tax, Corporate Tax
  • Type: Business and industry issue
  • Date: 09/09/2010

Tax Disputes Resolution 

Tax Dispute

We enable clients to unlock value tied-up in unresolved tax issues. The current financial environment has increased pressure on tax receipts and on businesses to add value and manage cash. If your business has open or emerging tax issues KPMG’s Tax Dispute Resolution network can help you achieve resolution quickly and effectively, Obtaining certainty on your tax issues will enable your business to realise benefits and value from reaching agreement with HM Revenue and Customs (HMRC).



Disputes can arise across all taxes and occur for a variety of reasons. KPMG’s Dispute Resolution team can help through all stages of the dispute lifespan, 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 minimise disruption to your business. We can assist you at all stages of an enquiry process from responding to opening notices and information requests through to obtaining closure notices.
  • Dispute resolution – assistance with alternative resolution solutions for more complex disputes. We can assist you develop tax dispute resolution strategies that align to your business objectives and enable you to quickly evaluate potential settlement outcomes whether through negotiation 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 will benefit from assistance by people who are experts in this field. We know the processes. We know the people. We get results.


What's on your Mind?


Does your business have ongoing tax enquiries or emerging issues and would benefit from professional help in progressing resolution with HMRC. Possible triggers could include:


  • 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 so more likely to target you for intense intervention
  • Change in the business (merger/acquisition), management team or tax strategy that provides an opportunity for a new relationship with HMRC
  • An open tax position(s) resulting in tax reporting issues, large provisions, uncertainty on availability of losses, cash tax on account with HMRC pending resolution
  • Tax planning / restructuring transaction being implemented where it is known that HMRC are likely to have a different view of the tax analysis
  • Pending litigation.


Bringing you Peace of Mind


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 a large number of significant tax settlements through formal HMRC resolution programmes including:


  • High Risk Corporates Programme (HRCP) for businesses dealt with by HMRC Large Business
  • Alternative Dispute Resolution (ADR) for disputes capable of resolution using mediation techniques
  • Assisting clients prepare settlement proposals  for consideration by HMRC’s Large Business Disputes Resolution Board (LBDRB) and also the Tax Disputes Resolution Board (TDRB)


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.


Our methodology incorporates a phased approach to help organisations progress disputed tax issues towards resolution with HMRC. Our approach aims to help organisations resolve difficult disputes collaboratively with HMRC. Where the chosen option for resolution is litigation our approach is to help manage this in a non-confrontational way. We can facilitate the resolution of contentious issues whilst enabling organisations to stay in control of the process


What's in it for you?


Potential benefits can include:


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




Through our experience of recent significant projects we have a network of relationships with HMRC and a proven approach to dispute resolution:


  • Our multi-disciplinary team has industry-leading skills in tax dispute management, which not only deliver clients the right outcome when settling historic issues, but also secures 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 and strong relationships with key senior HMRC people established through working successful dispute resolution projects


We know the processes. We know the people. We get results.


Case Study


Following a takeover we worked with the Parent group and HMRC to resolve significant inherited disputed tax issues. The Parent wanted to progress the disputed issues to resolution quickly, whilst securing appropriate value, and improving their relationship with HMRC.


We worked with the client to develop a base case of possible resolution scenarios and engaged with HMRC, to agree a process to enable the disputed issues to be resolved. We acted as intermediary on several levels - strategic oversight, project management and technical resource/negotiation on certain issues. The project achieved resolution of a range of direct & indirect tax issues spanning several years.


The client secured the desired benefit from negotiated settlement of many items resulting in release of significant provisions. The client received a greatly improved risk assessment from HMRC and we helped them develop and implement a new working relationship to give both parties earlier certainty on future emerging tax issues.






Paul Harrison

Tax Partner

 020 7311 3053


Julie Hughff

Tax Partner

 020 7311 3287


Amanda Brown

  Legal Services Partner

 020 7311 4728


Kevin Elliott

Tax Director

 020 7311 2487



Paul – has over 20 years experience of resolving contentious tax issues as both a senior tax authority investigator and as head of KPMG’s UK Tax Settlements & Investigations practice. Paul has lead a large number of significant tax settlement projects including HRCP and MCRP projects.


Julie – has extensive knowledge of HMRC, their people and processes having been on secondment for 12 months leading the  Review of Links with Businesses in 2006.  She  received an award in November 2010 recognising her contribution to promoting the benefits of greater transparency in tax through her work both on the Review of Links and subsequently. Julie applies her knowledge to assist clients engage effectively with HMRC in resolving a range of tax disputes.


Amanda – is a Partner in KPMG’s UK Tax Legal Services and has deep experience of litigating tax disputes over a period of nearly 20 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 25 years experience of working tax disputes both as a senior tax authority investigator and member of KPMG’s Tax Settlements & Investigations practice. Kevin has project managed a large number of significant tax settlement projects and acts as a mediator in ADR cases as a CEDR accredited mediator.


A Global Service

Our international clients deal with tax authorities all around the world and so can be in dispute with tax authorities all around the world. The way each authority deals with taxpayers and with disputes varies greatly and our clients need easy access to local knowledge to help them develop their strategy and manage their disputes. Our global Tax Dispute Resolution and Controversy network means we can provide our clients with the benefit of KPMG’s experience and insight wherever they have an issue.


HMRC said Julie Hughff was given the award for "persuading clients of the benefits of good relationships between business and tax administrations, the early clarification of key business issues and her open-minded approach to the resolution of technical issues."