Welcome to the spring 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other 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 the latest in relation to permanent establishment and diverted profits tax and the latest series of HMRC nudge campaigns. We also cover a number of notable tax cases and other interesting procedural decisions. This includes the most recent case law development on the unallowable purpose test within the loan relationship rules and a case from the tribunals in which the taxpayer alleged that HMRC was seeking to “cherry pick” by bringing the weakest case before the tribunal.
