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AI in tax disputes: risks and routes of challenge
Liesl Fichardt
Emily Au
Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in
tax disputes and the implications for transparency, fairness and taxpayer
challenges.
Contentious tax quarterly: Spring 2026
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) review recent decisions on costs for unreasonable behaviour, the use of AI in litigation and the scope of the FTT’s jurisdiction, as well as increased HMRC criminal investigations into advisers.
Private client review for March 2026
Sophie Dworetzsky
From AI in court to IHT and judicial review, Sophie Dworetzsky
(Lombard Odier) reviews the latest developments.
How AI can help democratise tax administration
Stephen Daly
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
Private client review for February 2026
Sophie Dworetzsky
Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
R&D tax in 2025: the calm after the storm?
Jenny Tragner
Jennifer Tragner (S&W) considers an unsettled year for R&D reliefs, where
transitional rules, evolving guidance and emerging AI questions kept advisers
busy despite few new policy changes.
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
A year at the Tax Bar in 2025
David Yates
David Yates KC (Pump Court Tax Chambers) reflects on a year marked by
unpredictable litigation, shifting private client rules and the evolving realities
of practice at the Tax Bar.
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
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EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Broad opposition to proposed ‘reckless statements’ tax offence
GfC7 points to disclosure facility for late TP corrections
Options explored for simplifying offshore anti-avoidance rules
CIOT calls for urgent changes on IHT on pensions
Normal minimum pension age protection consultation
CASES
Read all
HMRC v G Quillan
Perenco UK Ltd v HMRC
HMRC v C Candy
Property 118 Ltd and another v HMRC
Ten cases shaping tax practice in 2026
IN BRIEF
Read all
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
HMRC’s annual report for 2025/26
MOST READ
Read all
Tax Journal thanks its July 2026 authors
Property 118 Ltd and another v HMRC
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
The end of offshore execution on secondary transactions