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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
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
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
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 26 September 2025
HMRC to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
Read all
P Collingwood v HMRC
The hidden costs of a cap on lifetime gifting
The future of international tax reform
UK-Vietnam tax treaty updated
The Prudential Assurance Company Ltd v HMRC