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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: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
CASES
Read all
Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
Other cases that caught our eye: 5 September 2025
IN BRIEF
Read all
Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
MOST READ
Read all
First failure to prevent the facilitation of tax evasion case
T Masters v HMRC
Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC