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When Tax gets contentious

Top 10 problem areas

Hayley Ives
06/01/2026
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There are many reasons why a tax matter can turn contentious.

For clients, the focus should not be on why the issue arose, but on how we manage it going forward.

It is important to note that investigations by tax authorities are not the only source of contentious tax matters. Other common situations that result in problems include.

  • Disagreements between business partners.
  • Hostile divorce proceedings involving financial accusations.
  • Due diligence during company sales or purchases uncovering hidden issues.
  • Employment disputes linked to tribunal hearings.
  • Family conflicts where tax wrongdoing is suspected or alleged.
  • Inheritance disputes – uncertainty about the origin or distribution of funds.
  • Wealthy individuals living in high-value properties, particularly those owned by offshore structures.
  • Use of complex offshore tax structures, often perceived by HMRC as offshore avoidance.
  • Media reports – sometimes based on inaccurate assumptions.
  • Unexpected windfalls creating jealousy and leading to whistleblower reports.

Everyday events can unexpectedly bring tax matters to the surface — often with serious consequences. 

With HMRC’s new regime offering financial incentives to informants, the risk of known and perceived issues being investigated is increasing. This heightened scrutiny means that businesses and individuals alike must be prepared to address tax concerns swiftly and effectively.

Responding professionally to contentious tax matters is critical. Our experts are here to guide you through what you need to know and help you take the right steps forward.

For further information or advice, get in touch with a member of Crowe’s Tax Resolutions team or your usual Crowe contact.

Contact us


Hayley Ives
Hayley Ives
Partner, Tax ResolutionsLondon

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