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Tax disputes
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Tax disputes
TAX-DISPUTES
Contentious tax quarterly: Summer 2025
Adam Craggs
Liam McKay
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
Adam Craggs
Liam McKay
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
Adam Craggs
Liam McKay
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.
Go City: end of the road for ‘protective assessments’?
Bryn Reynolds
A recent FTT decision provides a startling level of insight into HMRC’s
decision making process, writes Bryn Reynolds (Pinsent Masons).
Other cases that caught our eye: 9 February 2024
Estoppel in tax disputes: In A Cattrell v HMRC [2024] UKFTT 67 (TC) (16 January 2024), the FTT dismissed the taxpayer's appeal against the validity of HMRC's closure notice in respect of an enquiry into the taxpayer's self-assessment return (which...
Resolving large business tax disputes: what more should be done?
Stephen Daly
Stephen Daly (King’s College London) reports findings from a recent study suggesting the need for greater transparency and training at HMRC, as well as a rebalancing of the tax administration framework.
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EDITOR'S PICK
Medpro: better late than never
Stacey Cranmore
1 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
2 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
3 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
4 /7
Understanding the FIG regime
Jo Bateson
5 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
6 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
7 /7
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
NEWS
Read all
HMRC appoint R&D expert advisory panel
Special tax sites designated in Wales
CIOT on tax barriers to housing supply
Repayment interest and commercial restitution for VAT
Italy plans to raise flat tax for wealthy new residents by 50%
CASES
Read all
Lands Luo Ltd v HMRC
Investment and Securities Trust Ltd v HMRC
Scott Brothers Ltd v HMRC
Other cases that caught our eye: 24 October 2025
Mainpay Ltd v HMRC
IN BRIEF
Read all
Autumn Budget 2025: what tax measures can we expect?
Taking cover
More on s 455
HMRC’s technical note on RIFs
HMRC’s new NIC guidance on internationally mobile employees
MOST READ
Read all
Autumn Budget 2025: what tax measures can we expect?
HMRC manual changes: 17 October 2025
HMRC manual changes: 10 October 2025
Mainpay Ltd v HMRC
Management expenses: HMRC’s new nudge campaign