Tax Disputes and Investigations – July 2025

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...
Tax Disputes and Investigations – July 2025

Tax Disputes and Investigations -October 2024

In this newsletter, we explore three key areas of tax disputes and investigations. First, the importance of carefully managing Alternative Dispute Resolution with HMRC, illustrated by a cautionary tribunal case where a poorly drafted exit agreement left a taxpayer...