On 9 May 2024, Anastasia Nourescu and Guy Bud from our Tax Litigation and Resolution team presented a webinar on Lexology outlining how taxpayers can manage UK tax disputes.

This session is designed to benefit in-house tax and legal teams as well as tax advisers across all areas of tax. Anastasia and Guy identify different types of disputes with HMRC, set out the main stages of such disputes, and provide practical tips for reaching a resolution.

The masterclass session covers:

  • HMRC’s assessment powers
  • How to deal with enquiries
  • Appeals to the Tax Tribunal
  • Judicial review challenges
  • Alternative dispute resolution

Watch the webinar in full here:  

Resolving disputes with HMRC: key points

The UK has one of the most advanced and complex tax codes in the world, inevitably causing disagreements with HMRC – which also has a mandate to substantially increase collections and is paying close attention to the tax affairs of corporates and high-net-worth individuals. The result is a large volume of disputes across the range of direct and indirect taxes.

Taxpayers self-assess their own liabilities for most UK taxes. The self-assessment system is required to strike a balance between HMRC’s duty to ensure that assessment is correct, and the taxpayer’s need for legal certainty and finality. HMRC has the ability to intervene based around time limits, along with additional criteria such as taxpayer conduct.

HMRC has far-reaching powers to compel taxpayers and third-parties to provide relevant information through ‘information notices’. Each has conditions to be met and in some instances there are grounds to appeal, though special penalties are in place for non-compliance.

As part of the webinar, Anastasia and Guy explain the process of responding to and challenging an HMRC decision. Taxpayers can choose to either accept the conclusions of HMRC’s assessment of their liabilities, request an independent review, or appeal on one of a range of grounds. Strict time limits apply in these cases.

Other questions answered include:

  • What are the different routes to appealing an HMRC decision?
  • How does the Tax Tribunal system work?
  • What is judicial review?
  • What is ADR in a tax context?



You can find further information regarding our expertise, experience and team on our Tax Litigation and Resolution page.

If you require assistance from our team, please contact us.



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