Tax controversy and litigation

Tax investigations and disputes require immediate and expert advice to meet strict deadlines. With our tax expertise and our experience dealing with Inland Revenue, and supported by our litigation experts, we are ready to help.

As tax lawyers, all confidential communications with you that provide legal advice or assistance are privileged from disclosure to Inland Revenue. That is a major advantage when compared to using tax accountants, who can be required to disclose your factual information to Inland Revenue.

Our focus is on eliminating or minimising your liability, while ensuring that your rights are fully protected. We work constructively with Inland Revenue to comply with its requests in a way that puts you in the best possible position. 

We represent individuals, financial institutions, corporates, and charities in significant tax disputes. Our tax experience includes advising on risk reviews, audits, and navigating clients through the formal tax dispute procedures.

We can help with:

• Representing clients in tax risk reviews and audits initiated by Inland Revenue, ensuring that only the necessary responses and documents are provided.
• Preparing tax dispute documents, including notices of proposed adjustment and response, statements of position, and attending mediation conferences.
• Making voluntary disclosures for clients to correct tax returns in a manner that reduces the imposition of penalties.
• Drafting settlement deeds and arranging tax payments using tax pooling to reduce the imposition of penalties and interest.
• Representing clients in court proceedings.
• Assisting clients with submissions to the Customs Service.

Recent highlights

New Zealand’s largest defective building case

Providing expert GST analysis for Auckland Council in connection with New Zealand’s largest defective building hearing in the High Court to date.

Navigating tax dispute procedures

Representing individuals throughout the tax dispute procedures and in settlement negotiations with Inland Revenue, including issues such as tax residency, the application of the foreign investment fund regime, the availability of tax losses and GST on property developments.

Making voluntary disclosures

Drafting voluntary disclosures for clients to reduce the application of penalties, including issues such unpaid PAYE on offshore bonuses and the attribution of income from limited partnerships.

Offshore trust audit

Negotiations with Inland Revenue on the proper application of the trusts’ regime to an international trust with New Zealand and foreign beneficiaries.

International GST matter 

Representing a multinational client on all aspects of a significant GST matter.