White Collar, Crime & Investigations

Tax Litigation & Investigations

a calculator sitting on top of a table next to a laptop
a calculator sitting on top of a table next to a laptop

We offer unrivalled expertise in civil fraud and asset recovery disputes including those that arise from bribery, corruption, breach of trust and fiduciary duty, POCA and asset forfeiture. 
Members act for individuals (including HNW), large corporates, banks and government entities including in relation to sovereign recovery.  

We act not only in civil fraud asset recovery but also criminal fraud proceedings, and there is often interaction between civil and criminal investigations and proceedings. Victims of fraud may have the option to pursue their losses/claim in either the civil or criminal courts and we are uniquely placed to act and advise on consequences and strategies in both options. 

Members are regularly instructed in relation to enforcement proceedings to recover assets arising from a judgments or arbitral awards in multi jurisdictions, and we have done so for many years in both the civil and criminal context. This spans multi jurisdictions throughout Europe, CIS, Middle East, US and Caribbean, Asia -Pacific and Africa. 

We also have specialist experience of sovereign asset recovery, not only in recovering assets but working with governments to assist with capacity building and ensuring their anti-corruption programmes are up to date. 

Representative cases

View cases

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

Field Opportunities v HMRC.

Intervening third party corporate applicant (s.301 PoCA). Defeated allegation of Directors’ corruption.

HMRC v PS, THL

Assisted with urgent advice on a civil tax fraud investigation (COP 8), including as to the risk of civil evasion penalties.

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

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.

Acting for the MR in VAT/Tax fraud criminal proceedings with a loss valued at plus £70m. Trial concluded April 2023 with D convicted.

R v Arif Patel & Ors

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

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

Nuttall & Others v HMRC.

Account freezing proceedings; AFO applications withdrawn following representations.

HMRC v X

Advised the Respondent to account forfeiture proceedings brought by Kent Police, and parallel tax tribunal proceedings against HMRC.

HMRC v X

Representing the Defendant in a criminal trial charged with attempting to cheat the revenue by claiming a VAT refund of £4,166,674.00.

R v Darryl Lee (2018)

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.

Malde & Others v HMRC.

Representative cases

View cases

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

Field Opportunities v HMRC.

Intervening third party corporate applicant (s.301 PoCA). Defeated allegation of Directors’ corruption.

HMRC v PS, THL

Assisted with urgent advice on a civil tax fraud investigation (COP 8), including as to the risk of civil evasion penalties.

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

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.

Acting for the MR in VAT/Tax fraud criminal proceedings with a loss valued at plus £70m. Trial concluded April 2023 with D convicted.

R v Arif Patel & Ors

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

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

Nuttall & Others v HMRC.

Account freezing proceedings; AFO applications withdrawn following representations.

HMRC v X

Advised the Respondent to account forfeiture proceedings brought by Kent Police, and parallel tax tribunal proceedings against HMRC.

HMRC v X

Representing the Defendant in a criminal trial charged with attempting to cheat the revenue by claiming a VAT refund of £4,166,674.00.

R v Darryl Lee (2018)

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.

Malde & Others v HMRC.

Representative cases

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

Field Opportunities v HMRC.

Intervening third party corporate applicant (s.301 PoCA). Defeated allegation of Directors’ corruption.

HMRC v PS, THL

Assisted with urgent advice on a civil tax fraud investigation (COP 8), including as to the risk of civil evasion penalties.

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

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.

Acting for the MR in VAT/Tax fraud criminal proceedings with a loss valued at plus £70m. Trial concluded April 2023 with D convicted.

R v Arif Patel & Ors

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

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

Nuttall & Others v HMRC.

Account freezing proceedings; AFO applications withdrawn following representations.

HMRC v X

Advised the Respondent to account forfeiture proceedings brought by Kent Police, and parallel tax tribunal proceedings against HMRC.

HMRC v X

Representing the Defendant in a criminal trial charged with attempting to cheat the revenue by claiming a VAT refund of £4,166,674.00.

R v Darryl Lee (2018)

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.

Malde & Others v HMRC.

For a confidential conversation please contact Chief Executive and Director of Clerking, Sam Carter.

For enquiries please contact our clerks

“The clerks always go above and beyond to assist. They understand the needs of instructing solicitors, particularly in identifying suitable counsel for cases”

  • Chambers & Partners

“A friendly and integrated service. The clerks systems and client handling are excellent - with a can-do attitude, enabling easier planning on my side.”

  • Legal 500

For a confidential conversation please contact Chief Executive and Director of Clerking, Sam Carter.

For enquiries please contact our clerks

“The clerks always go above and beyond to assist. They understand the needs of instructing solicitors, particularly in identifying suitable counsel for cases”

  • Chambers & Partners

“A friendly and integrated service. The clerks systems and client handling are excellent - with a can-do attitude, enabling easier planning on my side.”

  • Legal 500

For a confidential conversation please contact Chief Executive and Director of Clerking, Sam Carter.

For enquiries please contact our clerks

“The clerks always go above and beyond to assist. They understand the needs of instructing solicitors, particularly in identifying suitable counsel for cases”

  • Chambers & Partners

“A friendly and integrated service. The clerks systems and client handling are excellent - with a can-do attitude, enabling easier planning on my side.”

  • Legal 500