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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...
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...
The spectre of Albert Venn Dicey, the greatest of Victorian constitutionalists, looms large at the feast. In Skatteforvaltningen v Solo...
Multinational companies increasingly face situations where two or more countries seek to tax the same profits. Recently enacted and...
As mentioned in my earlier post, the UK’s proposed “Financial Institution Notices” (FINs) would give HMRC easier and quicker access to...
Looking at the CJEU decision in Luxembourg v B in the context of the UK's proposed new Financial Institution Notice (which would allow...
The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from...