Tax Disputes Digest - Autumn 2025 Edition
Welcome to the autumn 2025 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for tax and legal in-house professionals.
As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs. In this edition, we look at just a few of these developments, including in relation to unallowable purpose disputes.
We also cover a number of notable tax cases and other interesting procedural decisions. This includes the most recent case law development on determining the “place of effective management” in the context of the residence of trustees for the purposes of a double tax treaty and a significant caselaw development in the oil and gas space.
