Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the reiteration of government promises not to increase taxes on working people, it can be expected that HMRC will continue to seek to boost tax revenues through increased compliance activity. 

The Labour party’s election manifesto of June 2024 had already promised a “renewed focus on tax avoidance by large businesses”. The Autumn Budget 2024 announced that investment in HMRC compliance staff would raise “£2.7 billion per year in additional revenue by 2029-30”. And the numbers for both investment in compliance staff and expected additional revenues have since increased. 

What can you do to prepare?

Follow our blog post series! 

Over the next few weeks, we will publish a series of blog posts to take you through the tax disputes process in the UK from initial engagement – is it an “enquiry” or an “Enquiry”? – to settlement or litigation.

We will share our experience and practical tips, including what to do when HMRC first open an enquiry, how best to frame your appeal if you head towards litigation, and what to do when something goes wrong – for example if you have inadvertently shared documents that are subject to legal professional privilege. 

How we can help…

We have extensive experience in advising at every stage of a wide range of disputes from questions of UK corporation tax, partnership taxation and VAT grouping to treaty interpretation and transfer pricing. 

Whether you are looking for strategic advice in respect of an ongoing issue or proactive risk management through the creation of defence files or an audit of existing processes, we can help. 

So, please get in touch with me or another member of Slaughter and May’s market-leading tax disputes team.