Tax Disputes Digest - Autumn 2026 Edition
Welcome to the Autumn 2026 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 a range of areas. Both individual and corporate taxpayers would be well advised to review their tax affairs and governance processes to prepare for potential HMRC enquiry, investigation or dispute activity.
In this edition, we explore a number of significant developments, including recent publications highlighting HMRC's performance, compliance activity and transformation plans, as well as an important High Court decision on the scope of legal advice privilege for internal communications within corporate groups. We also examine key legislative, policy and consultation developments, together with the latest HMRC guidance, reports and nudge letter campaigns that may affect taxpayers and advisers alike.
