Tax Investigations

Devereux offers specialist silks and juniors with considerable advisory and litigation experience on the complex issues arising in tax investigation cases involving allegations of tax avoidance and tax evasion, including:

  • Code of Practice 8 (fraud and bespoke avoidance)
  • Code of Practice 9 (fraud) – contractual disclosure facility (CDF)
  • Criminal investigations and prosecutions
  • HMRC specialist investigations
  • VAT civil penalty investigations
  • HMRC investigation powers (information notices, production orders, and search warrants)
  • Discovery assessments
  • Part 6 of the Proceeds of Crime Act 2002 (Revenue functions)
  • Offshore disclosure facilities (Liechtenstein Disclosure Facility (LDF), etc)
  • Disclosure of tax avoidance schemes (DOTAS)
  • Promoters of tax avoidance schemes (Finance Act 2014, Part 5)
  • Accelerated payments
  • The General Anti-Abuse Rule (GAAR)

Members have considerable experience in cases involving all types of tax avoidance and tax evasion including investigations and disputes involving sideways relief, tax film schemes, offshore income, MTIC (carousel) and directors’ liability for outstanding VAT.

The reputation and expertise of Devereux’s tax practitioners is reflected in the legal directories. A list of relevant cases and appointments is included within each individual barrister’s personal profile.

Barristers with Expertise in this area

King’s Counsel


Felicity Cullen KC

Silk 2008 | Call 1985

Aparna Nathan KC

Silk 2019 | Call 1994

Marika Lemos KC

Silk 2025 | Call 2002

David Bedenham KC

Silk 2025 | Call 2005

Junior Counsel


Barrie Akin

Call 1976

Ashley Greenbank

Call 2025 1988

Rebecca Murray

Call 2001

Joshua Carey

Call 2015

Max Schofield

Call 2016