Tax Disputes and Investigations – May 2026

Tax Disputes and Investigations – May 2026

In this newsletter, we look at some issues which practitioners frequently face when managing disputes with HMRC. What is the right approach to dealing with careless behaviour when professional advice has been taken? What happens if there is a lack of contemporaneous...
Tax Disputes and Investigations – May 2026

Tax Disputes and Investigations – March 2026

In this edition, we cover a range of significant developments in UK tax disputes and investigations. We share our recent experience on MTIC and HMRC internal reviews, and analyse the First-tier Tribunal’s striking findings in HMRC v Harte, where HMRC’s approach...
Code of Practice 9 (COP9)

Code of Practice 9 (COP9)

Receiving a Code of Practice 9 (COP9) letter from HMRC is a serious matter that requires immediate attention. This letter indicates that HMRC suspects deliberate tax fraud has taken place and initiates a formal investigation. How you respond in the coming weeks can...
Tax Disputes and Investigations – May 2026

Tax Disputes and Investigations – July 2025

HMRC reactivates enquiries into unallowable purpose Ben Proctor HMRC has been writing to taxpayers with open enquiries involving the unallowable purpose rule at Section 441 CTA 2009. The letters invite taxpayers to reconsider their position in light of three Court of...