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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
Daniel Williams
Michelle Sloane
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
Adam Craggs
Liam McKay
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?
Bridget Winters
Calum Young
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.
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
Other cases that caught our eye: 14 November 2025
Judicial review determining tax residency: K (oao R Houldsworth) v HMRC [2025] EWHC 2848 (Admin) (4 November) revisits an issue which many people might have thought had gone away: the extent to which the (former) IR20 booklet can be relied on when...
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC to accept Advance Tax Certainty expressions of interest from 1 June
State Opening of Parliament 2026
IHT and pensions from April 2027: HMRC set out operational detail
TRF: clarification on trusts
GAAR Advisory Panel opinion
CASES
Read all
J Krason v HMRC
British Institute of Technology Ltd v HMRC
J Nuttall and another v HMRC
Other cases that caught our eye: 15 May 2026
Professional Game Match Officials Ltd v HMRC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Madsen: discovery assessments
Other cases that caught our eye: 8 May 2026
HMRC’s transfer pricing windfall: one-off or new normal?
M Parker v HMRC
Burlington: towards an international fiscal meaning of ‘main purpose’