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Contentious tax: 2023 mid-year review

Speed read
Reflecting on the contentious tax landscape at the mid-year point, HMRC’s performance is once again under the spotlight with the PAC report being published and HMRC’s TP and DPT statistics for 2021/22, with the overall assessment being something of a mixed bag. Meanwhile, the tribunals and courts continue to strive to improve certainty in respect of important procedural issues (for example, what constitutes an appealable decision, when new arguments will be permitted at later appeal stages and the test for whether a tribunal/court has made a material error of law).

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