Liam McKay

Of Counsel

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London

Liam is an experienced tax litigator and advises corporate and individual clients on contentious tax disputes across the spectrum of direct and indirect taxes. With a particular interest in the tech industry, high-net-worth individuals, and tax disputes involving cryptocurrency, Liam has extensive litigation experience at all levels of the tribunals and courts, with expertise in judicial review and civil proceedings in the ordinary courts. He has broad experience in cross-border tax disputes, including disputes concerning anti-dumping duty and transfer pricing issues.

"Clients need more than technical tax advice – they need a strategist who knows and can navigate HMRC's internal processes, while keeping sight of the commercial objective."

"Before joining RPC, I was a lawyer in the Strategic Tax Litigation Team within HMRC Solicitor's Office, where I acted on many of HMRC's most significant tax disputes. That experience gives me valuable insight into HMRC's decision-making, litigation strategy and internal processes, enabling me to anticipate issues and develop effective strategies for resolving disputes. Clients need more than technical tax advice – they need a strategist who knows and can navigate HMRC's internal processes, while keeping sight of the commercial objective.

Tax disputes are rarely just about tax – they're about protecting businesses, reputations and peace of mind. I am known for providing clear, pragmatic and commercially focused advice. I work closely with clients to develop litigation strategies aligned with their wider objectives, whether that means achieving an early resolution or pursuing proceedings through to trial. Clients value my responsiveness, strategic judgement and ability to explain complex issues in straightforward terms."

Liam's recent work highlights:

Acting for Currys Retail Limited in significant litigation concerning a c.£30 million corporation tax liability arising from the application of the degrouping charge provisions.

Acting for two electricity generation companies in complex tax litigation concerning the availability of Enterprise Investment Scheme (EIS) relief for investments in gas peaking power generation projects, raising important issues as to when a qualifying trade is treated as having commenced for EIS purposes.

Acting for a HNW individual in respect of a long-running HMRC enquiry into domicile and the taxability of various offshore structures.

Acting for Frasers Group in a c.£23 million customs dispute concerning anti-dumping duties arising from an investigation by the European Anti-Fraud Office (OLAF) into bicycles imported from Sri Lanka.

Successfully representing the taxpayer, a Japanese-owned semiconductor company, in Dialog Semiconductor Limited v HMRC [2025] UKFTT 1188 (TC), a high-value tax dispute concerning the tax treatment of a US$137.3 million merger termination fee.

Successfully representing a major property developer in tribunal and judicial review proceedings arising from a dispute with HMRC concerning the VAT treatment of remedial cladding works.