Tax UK Notes

Court grants extension of time to pursue JR despite "unjustified delay"

Classification of foreign dividends

HMRC consult on changes to dispute resolution

Third party access to pleadings in the FTT

In Cider of Sweden Ltd v HMRC (Ernst & Young LLP (Third Party)) [2022] UKFTT 76 (TC), the First-tier Tribunal ("FTT") has issued a …

Kandore: information notices and the limits of open justice

HMRC's powers under Schedule 36 Finance Act 2008 ("Schedule 36") to obtain information relating to a taxpayer's affairs from a third …

Tax Appeals: Don't Forget ADR

The President of the First-tier Tribunal (Tax) (the "Tribunal”) has today published a practice statement (the “Statement”) on the …

Getting Justice in the Tribunal

This note is principally about two Supreme Court cases, R (on the application of UNISON) v Lord Chancellor [2017] UKSC 51 ("the fees case") and …

The Limits of HMRC's Powers of Investigation

In support of HMRC's powers to enquire into and investigate taxpayers' affairs, Parliament has conferred upon HMRC powers to require taxpayers …

Alternatives to Litigation

HMRC is responsible for the collection and management of tax in the UK.  It has a wide discretion in doing so, and in how it goes about litigating …