PENALTY

Another procedural layer bolted onto an already intricate system.

Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

As 2026 passes its halfway point, we take stock of a busy year in the courts. From decisions on partnership tax and treaty abuse to VAT, inheritance tax planning to employment status, here is our pick of ten key cases shaping tax practice this year....

SKAT fraud claim survives issue estoppel challenge: Readers may recall SKAT’s attempt to pursue a fresh fraud claim in England against MCML, formerly ED&F Man Capital Markets Ltd, over allegedly false tax vouchers used to obtain Danish...

Follower notices and corrective action: C Maguire v HMRC [2026] UKFTT 929 (TC) (18 June) is a rare example of a taxpayer succeeding in an appeal against a penalty for failing to take corrective action after receiving a follower notice. The taxpayer...

Penalties: reliance on trusted accountant

Re-litigating the same issue