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JUDICIAL-REVIEW


Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.
From AI in court to IHT and judicial review, Sophie Dworetzsky (Lombard Odier) reviews the latest developments.
The Government might have consulted but it hasn’t listened.
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).
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).
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.
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.
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...
High Court dismisses JR challenge to HMRC data-sharing with Spain
HMRC’s revised view of UK–Spain treaty residence not amenable to judicial review
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