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BLOG: How to respond to information requests from HMRC A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes in the UK, we discussed what to look out for when HMRC open an enquiry – and noted that enquiries often...
BLOG: Privilege in UK tax disputes: Five questions answered HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask for them. Careful thought is required when assessing if a document really is privileged (and so can be withheld) and,...
BLOG: Supreme Court in Prudential Assurance clarifies interaction of VAT grouping and time of supply rules Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for the services comprises a quarterly management fee and success fees. The success fees depend on investment performance...
BLOG: Can you rely on a tax treaty to progress an HMRC enquiry? 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 was said in the previous post of our series of blogs on tax disputes in the UK . Here, we consider...
BLOG: What happens when you take a UK tax dispute to the First-tier Tribunal? he First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The previous post in our series on tax disputes in the UK considered the first steps in challenging an HMRC...
BLOG: First steps in challenging a tax assessment in the UK 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 the next two posts, we will look at what happens next, focussing on corporation tax appeals, as opposed to...
BLOG: Inter-American Court of Human Rights: There is a Human Right to a Healthy Climate On 3 July 2025, the Inter-American Court of Human Rights (“IACHR”) handed down its advisory opinion on the climate emergency and human rights (the “IACHR Opinion”) which, among other conclusions, finds that there is a human right to a healthy climate...
BLOG: Appealing a UK tax case beyond the First-tier Tribunal: five points to consider 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 taxpayers will have found themselves wondering what to do following receipt of an unfavourable FTT decision. But the...
BLOG: Civil and criminal investigations by HMRC: Drawing the line So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on HMRC's civil and criminal processes for the investigation of the most serious forms of tax non-compliance, including...
BLOG: Bringing an HMRC enquiry to conclusion HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many years, with numerous requests for information. Compliance costs can mount and potentially awkward disclosures may need...