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Judicial review
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Judicial review
JUDICIAL-REVIEW
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.
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.
Legislation day 2025: The APR and BPR reforms: sobering reading
Stuart Maggs
The Government might have consulted but it hasn’t listened.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
Challenging HMRC’s debt management actions: lessons from Local Fuel
Michelle Sloane
Daniel Williams
A recent High Court decision provides valuable guidance for taxpayers
seeking to challenge enforcement action taken by HMRC’s Debt Management
team, write Michelle Sloane and Daniel Williams (RPC).
Contentious tax quarterly: Spring 2025
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.
Initiative and the tax tribunal: a higher calling?
Calum Young
Bridget Winters
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Other cases that caught our eye: 22 May 2026
Adjoining property was part of garden for SDLT purposes: Vereley Homes Ltd v HMRC [2026] UKFTT 695 (TC) (12 May) is another failed taxpayer appeal for SDLT mixed-use treatment. The only issue here was whether a separate, fenced plot (the former site...
R (oao Peter Kadas) v HMRC
High Court dismisses JR challenge to HMRC data-sharing with Spain
J Font v HMRC
HMRC’s revised view of UK–Spain treaty residence not amenable to judicial review
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5
EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
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
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
When Ramsay does not rescue HMRC
Tax and the City for July 2026
BlueCrest: the impact for asset managers
HMRC v BlueCrest Capital Management (UK) LLP