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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...
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...
In the fourth episode of our round the world Tax Disputes podcast series, we take you to India for a conversation with Mukesh Butani,...
Few tax cases manage to elicit such intractable feelings of crossness in me as the saga of HMRC v Tooth which has come to an end with the...
As mentioned in my earlier post, the UK’s proposed “Financial Institution Notices” (FINs) would give HMRC easier and quicker access to...
The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from...