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Tax disputes
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Tax disputes
TAX-DISPUTES
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.
Boulting: clarifying the purpose test in share buy-backs
David Whiscombe
Boulting
cannot be regarded as a satisfactory case, except as to its outcome in
favour of the taxpayer, writes David Whiscombe.
Lifecycle of a transaction: tax disputes on intra-group debt
Ravi Ahlawat
Lauren Redhead
Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when
HMRC enquire into deal funding, and provide a practical playbook from first
request to resolution.
Contentious tax quarterly: Summer 2025
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) review some notable rulings on a
range of procedural issues, as well as recent changes to the tribunal rules.
Private client review for June 2025
Sophie Dworetzsky
A long-awaited report on will reform and the recent announcement on
carried interest are among the developments covered in this month’s review
by Sophie Dworetzsky (Charles Russell Speechlys).
Improving HMRC’s approach to dispute resolution
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
Time is money: how to mitigate late payment interest in tax disputes
Jack Prytherch
Jack Prytherch (Osborne Clarke) sets out the practical steps that taxpayers
can take to minimise delays in their disputes with HMRC and so mitigate any
additional interest charged.
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Supreme Court denies enterprise zone allowances.
Alternative dispute resolution and mediation
Liam McKay
Adam Craggs
We are likely to see a consistent increase in the use of mediation in tax
disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is
in the taxpayer’s interests.
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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
Government confirms that no SDLT charge for tenants on periodic tenancies
HMRC step up VAT scrutiny as large and medium sized-business investigations rise 31%
Government announces increase to Electricity Generator Levy
CIR returns
HMRC issue updated VAT road fuel scale charges
CASES
Read all
HMRC v Burlington Loan Management DAC
HMRC v MR Currell Ltd
R Madsen v HMRC
Other cases that caught our eye: 1 May 2026
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
IN BRIEF
Read all
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
ATED: a reminder
UK short-term business visitors: the Appendix 4 report
Tax advisers: sanctionable conduct
MOST READ
Read all
Tax advisers: sanctionable conduct
Section 171A elections
HMRC loans to participators tool
Mega Marshmallows and the meaning of ‘normally’
Centrica Energy Storage Ltd v HMRC