Patrick Cannon advises individuals, firms and companies on tax litigation and tax-related commercial litigation against HMRC, and against other individuals and businesses in commercial disputes with a tax dimension. He also advises clients against professional advisers in relation to mis-sold tax schemes or negligent tax advice.
Some examples of Patrick Cannon’s work include:
- Litigation may be required in order to resolve claims for VAT liabilities and refunds arising out of supply chains, or in cases of carousel fraud.
- Disputes arising from tax deeds and warranties on the sale of businesses and the preparation of completion accounts and tax retentions may also require litigation in order to get another party to accept liability and pay up.
- Claims for professional negligence against professional tax advisers and tax scheme providers, where the failure to advise properly on the risks involved – including those of judicial and public scrutiny – make the adviser liable to pay compensation for losses suffered.
- Claims in the County Court by HMRC to enforce tax and national insurance contributions, where time limits or other procedural irregularities may be in issue.
- Claims by HMRC’s Debt Management group for tax-related debts and defending bankruptcy and insolvency proceedings, and what is a reasonable offer to pay tax debts by instalments.
- Claims by insolvency practitioners against directors of insolvent companies where HMRC is the principal creditor in respect of unpaid PAYE or NIC arising out of disguised remuneration schemes.