One minute with Dilpreet K Dhanoa, barrister at Field Court Tax Chambers
What’s keeping you busy at work?
A genuinely mixed bag – one of the pleasures of tax. I recently finished a hearing on what amounted to ‘exceptional circumstances’ for imports of PPE during Covid, and I am now juggling Kittel disputes, VAT supply issues and a tax-related judicial review, alongside advisory work on domicile and corporate criminal offences, with Managed Service Companies litigation on the horizon.
What do you know now that you wish you’d known at the start of your career?
That in complex tax disputes, the real difficulty is rarely the headline point of law. It is case-control: identifying the few determinations the tribunal must make, and stripping away everything that does not advance them. The route to that is simple but not easy: master the fundamentals early, and accept that the learning never ends. Tax looks deceptively neat in the abstract; it is only when you apply it to real transactions and imperfect records that the sharp edges appear.
Advocacy, particularly in tax, is a craft of judgement rather than force. The best submissions do not shout; they persuade because the tribunal trusts the advocate’s sense of proportion. Persuasion is earned by taking the tribunal through the documents and the authorities so that the conclusion feels like the natural destination. A good advocate does not merely point to the result – they lead the tribunal there.
If you could make one change to tax, what would it be?
It would be to bring more consistency and proportionality to how privilege is handled in tax disputes. In my experience, privilege is not about shielding the law; it protects the candour of the client/adviser relationship – the space where awkward questions can be asked and answered properly. The difficulty is that privilege can become a dispute within the dispute – with arguments over categories, redactions and ‘dominant purpose’ which end up consuming time and cost that would be better spent on the underlying tax issue.
Most tax cases are decided on facts, not labels. So the reform I would welcome is procedural: a tax-specific privilege protocol – early agreement of privilege categories, a properly informative privilege log, and (where needed) sampling by independent counsel. It safeguards the principle while keeping the litigation focused and proportionate.
Any new trends you’re seeing in tax?
First, administration and penalties are becoming a live battleground in their own right, not just a footnote to the underlying tax. The direction of travel is towards tighter compliance levers and more consistency across regimes (including the extension of the newer late submission/late payment penalty framework). The practical consequence is that procedural choices made early in an enquiry can drive exposure just as much as the substantive analysis.
Second, and something I have seen at close quarters through instructions in payroll/agency workers disputes, compliance is increasingly being engineered by reallocating risk within the supply chain, rather than by tinkering with rates or reliefs. The Finance Bill 2026 umbrella company measures illustrate the point: PAYE risk is pushed upstream by imposing joint and several liability on the agency (and in some circumstances the end client) where an umbrella fails to account for PAYE. The policy logic is clear: it is easier to influence behaviour by placing responsibility on the party with commercial leverage. The sting is equally clear: this is as much about governance and contracting as it is about tax.
Finally, you might not know this about me but...
I try to ring-fence time in my diary for pro bono work: whether that is volunteering via the Chancery Litigant in Person scheme, or helping out at my Inn. It is a useful reminder that law is a public service, and you can make a practical difference to the people around you.
One minute with Dilpreet K Dhanoa, barrister at Field Court Tax Chambers
What’s keeping you busy at work?
A genuinely mixed bag – one of the pleasures of tax. I recently finished a hearing on what amounted to ‘exceptional circumstances’ for imports of PPE during Covid, and I am now juggling Kittel disputes, VAT supply issues and a tax-related judicial review, alongside advisory work on domicile and corporate criminal offences, with Managed Service Companies litigation on the horizon.
What do you know now that you wish you’d known at the start of your career?
That in complex tax disputes, the real difficulty is rarely the headline point of law. It is case-control: identifying the few determinations the tribunal must make, and stripping away everything that does not advance them. The route to that is simple but not easy: master the fundamentals early, and accept that the learning never ends. Tax looks deceptively neat in the abstract; it is only when you apply it to real transactions and imperfect records that the sharp edges appear.
Advocacy, particularly in tax, is a craft of judgement rather than force. The best submissions do not shout; they persuade because the tribunal trusts the advocate’s sense of proportion. Persuasion is earned by taking the tribunal through the documents and the authorities so that the conclusion feels like the natural destination. A good advocate does not merely point to the result – they lead the tribunal there.
If you could make one change to tax, what would it be?
It would be to bring more consistency and proportionality to how privilege is handled in tax disputes. In my experience, privilege is not about shielding the law; it protects the candour of the client/adviser relationship – the space where awkward questions can be asked and answered properly. The difficulty is that privilege can become a dispute within the dispute – with arguments over categories, redactions and ‘dominant purpose’ which end up consuming time and cost that would be better spent on the underlying tax issue.
Most tax cases are decided on facts, not labels. So the reform I would welcome is procedural: a tax-specific privilege protocol – early agreement of privilege categories, a properly informative privilege log, and (where needed) sampling by independent counsel. It safeguards the principle while keeping the litigation focused and proportionate.
Any new trends you’re seeing in tax?
First, administration and penalties are becoming a live battleground in their own right, not just a footnote to the underlying tax. The direction of travel is towards tighter compliance levers and more consistency across regimes (including the extension of the newer late submission/late payment penalty framework). The practical consequence is that procedural choices made early in an enquiry can drive exposure just as much as the substantive analysis.
Second, and something I have seen at close quarters through instructions in payroll/agency workers disputes, compliance is increasingly being engineered by reallocating risk within the supply chain, rather than by tinkering with rates or reliefs. The Finance Bill 2026 umbrella company measures illustrate the point: PAYE risk is pushed upstream by imposing joint and several liability on the agency (and in some circumstances the end client) where an umbrella fails to account for PAYE. The policy logic is clear: it is easier to influence behaviour by placing responsibility on the party with commercial leverage. The sting is equally clear: this is as much about governance and contracting as it is about tax.
Finally, you might not know this about me but...
I try to ring-fence time in my diary for pro bono work: whether that is volunteering via the Chancery Litigant in Person scheme, or helping out at my Inn. It is a useful reminder that law is a public service, and you can make a practical difference to the people around you.
