Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Ftt
Home
Ftt
FTT
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.
Penalty suspension
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
BTR late than never: SDLT overpayment relief
Helen Coward
‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.
Headless chickens: Morrisons and the FTT’s supervisory jurisdiction
Yousuf Chughtai
Jack Prytherch
The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).
The VAT review for March 2026
Gary Barnett
Gary Barnett (Simmons & Simmons) reviews recent VAT developments, including the Upper Tribunal’s decision in Lycamobile and CJEU guidance on statutory payments.
Back to square one: late appeals after Medpro
Liam McKay
Adam Craggs
The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar
Martland
hurdle once again, write Adam Craggs and Liam McKay (RPC).
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Emily Osborne
The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).
TOMS, taxis and private hire vehicles
Damon Wright
Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.
Trouble in store for the Sehgals
John Shallcross
John Shallcross (Blake Morgan) examines the counter-intuitive result in a mixed property SDLT decision.
Go to page
of
17
EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime