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So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on...
With HMRC statistics showing that HMRC was successful (at least in part) in 93% of First-tier Tribunal (FTT) tax cases in 2024/25, many...
The First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The...
Previous posts in our series on tax disputes in the UK considered how an HMRC enquiry is likely to proceed and be concluded. In this and...
If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what...
HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many...
Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for...
HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask...
A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes...
Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of...
Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the...
Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in...
Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...
In October 2024, the UK Government announced as part of the budget that from 6 April 2027, “inherited pensions [will be brought] into...
The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation....
The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...