It depends on the tax and the stage. Some appeal routes require payment of a portion of the disputed amount, or of the tax admitted as due, before the appeal can be heard, while others do not. The required percentage and conditions are set by the relevant statute and can change through Finance Acts, so we check the current rule for each case. Where a deposit is required, we consider whether a stay or relief is available. Planning these payment decisions early is central to managing tax disputes efficiently. We set out the options clearly.

Time limits are short, generally measured in days from receipt of the assessment or order, and they differ between income tax, VAT and customs. Late appeals may be admitted only in limited circumstances and with a good explanation. Because missing a deadline can end a strong case, we treat the date of service of an order as the start of a strict countdown. If you have received an order, send it to us immediately with the date you received it, and we will confirm the deadline and the steps required. Deadlines are tracked centrally for every matter.

Often, yes. The tax and VAT laws provide for alternative dispute resolution, which allows a negotiated outcome with the involvement of a facilitator. Some disputes can also be resolved through rectification of an error, a revised submission or discussions with the assessing officer before a final order is made. Settlement is not always appropriate, particularly where an issue of principle affects many years. We help clients weigh the cost, time and certainty of settlement against the prospects and value of a full appeal in each of their tax disputes. We give a clear recommendation.

Contemporaneous documents are usually the most persuasive: contracts, invoices, bank records, board approvals, transfer pricing documentation, customs documents and correspondence explaining the commercial purpose of a transaction. Reconciliations between accounts and returns are also important. Evidence should be organised so that each adjustment can be answered with a specific document. In tax disputes, the record before the first appellate authority often limits what can be added later, so we gather and present evidence as completely as possible from the start of the process. Gaps can sometimes be filled with affidavits or third-party confirmations.

Yes, in appropriate cases. Questions of law arising from tribunal decisions can be taken to the High Court Division by reference or appeal, as the relevant statute provides. Where a demand has been made without legal authority, in breach of natural justice or contrary to the statute, a writ petition may be available, sometimes with interim relief. Courts generally expect statutory appeal routes to be used first, unless there is a clear reason they are inadequate. We assess which route fits the dispute and what interim protection is realistic. Interim orders can be time-limited.

The first step is to understand exactly how the tax authority reached its adjustment: the method used, the comparables selected and any assumptions about functions and risks. We then test that analysis against the group's documentation and economic evidence, often working with transfer pricing economists. Challenges proceed through the ordinary appeal route. Where an adjustment causes double taxation across countries, a mutual agreement procedure under the relevant double tax treaty may be available. Transfer pricing tax disputes benefit from coordination between local and group tax advisers. We plan the timetable carefully.

Time is critical, because demurrage and storage costs accumulate quickly. Options may include release on payment of the assessed duty under protest, release against a bank guarantee or bond, or an urgent application for review where permitted. At the same time, we prepare the substantive challenge to the classification or valuation, using product specifications, technical literature, previous assessments and relevant rulings. The aim is to release the goods promptly while preserving the right to recover any overpaid duty if the challenge succeeds. Tax disputes at port need quick decisions. Review invoices and product literature immediately.

They can. Banks and regulators may require evidence of tax compliance, such as tax clearance or certificates, before processing dividend remittances or certain other outward payments. An unresolved demand may delay these approvals. We advise on how to manage this, including whether payment under protest or a stay order could allow a remittance to proceed. Foreign investors should consider the potential timing impact of tax disputes when planning dividends, loan repayments or exits, and should seek advice before a remittance becomes urgent. We coordinate with your bank.