Search results

Please enter search term
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 fraud....
French Digital Services Tax: a French Tribunal rules in favor of the taxpayer on the concept of economically independent services from the taxable digital service The Administrative Tribunal of Cergy-Pontoise issued the first decision on the merits concerning the application of the French Digital Services Tax (DST) on 23 September 2025. This decision, favourable to the taxpayer, gives an example of what it means...
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...
Cyber supply chain risk but not as we know it…. The recent cyber attack at JLR not only demonstrates the debilitating nature of a severe cyber attack, but highlights the devastating impact this can have on an organisation’s supply chain.  We tend to think of the supply chain as being an in-bound risk...
CMA clarifies expectations on consumer reviews, but uncertainties remain Since the key consumer protection aspects of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) came into force in April, there has been a lot of focus on the new prohibitions relating to fake consumer reviews. With a recent report...
What happens when you take a UK tax dispute to the First-tier Tribunal? The 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 assessment. Here,...
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 indirect...
ICO Issues First Guidance on Distributed Ledger Technologies The UK Information Commissioner’s Office (ICO) has followed the European Data Protection Board (EDPB) in issuing draft  guidance on Distributed Ledger Technologies (DLTs), with finalised guidance expected in the winter of 2025/26. The ICO’s guidance is...
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 in more detail the...
Cookie catch-up: What you need to know about the CNIL’s Google and Shein fines (and other summer developments) At the start of September, the French data protection authority (the CNIL) issued record breaking cookie penalties against Google (€325 million) and online fashion retailer Shein (€150 million). With the UK’s cookie penalties set to increase at the end of...
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...
As the Data Act becomes applicable, what do you need to know? The EU’s flagship Data Act starts to apply today (12 September), marking a new phase for data sharing in the EU. The Data Act, an EU regulation (2023/2854), promises to enhance the EU’s data economy and facilitate data-driven innovation by increasing the...
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...
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,...
Spain’s National Court recognises non-EU taxpayers’ right to be taxed on a net basis, by deducting expenses against their Spanish source income In a landmark decision, Spain’s National Court (Audiencia Nacional) has applied CJEU case law on the free movement of capital to conclude that non-EU/EEA taxpayers subject to the Non-Resident Income Tax (NRIT) are entitled to deduct expenses directly...